DeHeng Law Offices
Legal Opinion on Shanghai Zhaomin New Materials Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Targets and Listing on the Shenzhen Stock Exchange
DeHeng Ref: 12F20250714-26
To: Shanghai Zhaomin New Materials Technology Co., Ltd.
Pursuant to the "Special Legal Consultation Service Agreement" signed between Shanghai Zhaomin New Materials Technology Co., Ltd. (hereinafter referred to as the "Issuer") and our firm, our firm has been entrusted by the Issuer to serve as its special legal advisor for the issuance of convertible corporate bonds to unspecified targets (hereinafter referred to as the "Current Issuance"). Our firm currently holds the "License for Practicing Law Firms" issued by the Beijing Municipal Bureau of Justice (Unified Social Credit Code: 31110000400000448M), with its registered address at 12th Floor, Block B, Fukai Building, Financial Street, Xicheng District, Beijing, and its responsible person is Ms. Wang Li. As of 2025, our firm had a total of 617 lawyers engaged in securities legal services.
In accordance with the "Company Law," "Securities Law," "Administrative Measures for Securities Legal Business of Law Firms," "Practice Rules for Securities Legal Business of Law Firms (Trial)," "Administrative Measures for Securities Issuance Registration of Listed Companies," "Compilation Rules for Information Disclosure of Publicly Issued Securities No. 12 - Legal Opinions and Lawyers' Work Reports on Publicly Issued Securities," and other relevant laws and regulations, as well as the relevant regulations of the China Securities Regulatory Commission (CSRC), and in accordance with the generally recognized professional standards, ethical norms, and diligence and conscientiousness of the Chinese legal profession, regarding the Current Issuance, our firm has issued the "Lawyers' Work Report of DeHeng Law Offices on Shanghai Zhaomin New Materials Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Targets" (hereinafter referred to as the "Work Report"), the "Legal Opinion of DeHeng Law Offices on Shanghai Zhaomin New Materials Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Targets" (hereinafter referred to as the "Legal Opinion"), the "Supplementary Legal Opinion (I) of DeHeng Law Offices on Shanghai Zhaomin New Materials Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Targets" (hereinafter referred to as "Supplementary Legal Opinion (I)"), and the "Supplementary Legal Opinion (II) of DeHeng Law Offices on Shanghai Zhaomin New Materials Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Targets" (hereinafter referred to as "Supplementary Legal Opinion (II)"), and the "Supplementary Legal Opinion (III) of DeHeng Law Offices on Shanghai Zhaomin New Materials Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Targets" (hereinafter referred to as "Supplementary Legal Opinion (III)").
Our firm hereby issues the "Legal Opinion of DeHeng Law Offices on Shanghai Zhaomin New Materials Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Targets and Listing on the Shenzhen Stock Exchange" (hereinafter referred to as the "Current Legal Opinion") regarding the Issuer's issuance of convertible corporate bonds to unspecified targets and listing on the Shenzhen Stock Exchange (hereinafter referred to as the "Current Issuance and Listing").
Declarations by our firm and our lawyers regarding the Current Legal Opinion: