Beijing Grandway Law Offices
Supplementary Legal Opinion I on Guangdong Shenling Environmental Systems Co., Ltd.'s Application for Issuance of Convertible Bonds to Unspecified Targets
Guo Feng Legal Certificate No. [2026] AN039-6
To: Guangdong Shenling Environmental Systems Co., Ltd.
Pursuant to the "Lawyer Service Agreement" signed between our firm and the issuer, our firm was entrusted by the issuer to serve as the special legal advisor for this issuance project.
Our lawyers have, in accordance with the "Company Law," "Securities Law," "Registration Management Measures," "Securities Legal Business Management Measures," "Securities Legal Business Practice Rules," and other laws, regulations, rules, normative documents, and relevant regulations of the China Securities Regulatory Commission and stock exchanges, and in accordance with the generally accepted business standards, ethical norms, and diligence spirit of the legal profession, inspected the documents and facts related to the issuer and this issuance, and have issued the "Legal Opinion of Beijing Grandway Law Offices on Guangdong Shenling Environmental Systems Co., Ltd.'s Application for Issuance of Convertible Bonds to Unspecified Targets" (hereinafter referred to as the "Legal Opinion"), the "Lawyer's Work Report of Beijing Grandway Law Offices on Guangdong Shenling Environmental Systems Co., Ltd.'s Application for Issuance of Convertible Bonds to Unspecified Targets" (hereinafter referred to as the "Lawyer's Work Report"), and other application documents.
Given that the issuer's situation has changed during the period from the issuance date of the aforementioned Legal Opinion to December 31, 2025 (hereinafter referred to as the "New Period"), the Huaxing Certified Public Accountants engaged by the issuer have issued the "Audit Report" with the serial number "Huaxing Shenzi [2026] 25013720025" after auditing the issuer's financial statements (including the balance sheet as of December 31, 2025, consolidated balance sheet, income statement and consolidated income statement for 2025, cash flow statement and consolidated cash flow statement). Our lawyers, based on further investigation of the issuer's situation related to this issuance, hereby issue this Supplementary Legal Opinion to modify, supplement, or provide further explanation on the relevant content of the Legal Opinion and Lawyer's Work Report previously issued by our lawyers.
Our lawyers agree that this Supplementary Legal Opinion will be submitted together with other materials as a statutory document required for the issuer's current issuance, and our firm will bear corresponding legal responsibilities for this Supplementary Legal Opinion; this Supplementary Legal Opinion is only for the purpose of the issuer's current issuance and shall not be used for any other purpose.
The statements made by our lawyers in the Legal Opinion and Lawyer's Work Report also apply to this Supplementary Legal Opinion. Unless otherwise specified, the meanings of the terms used in this Supplementary Legal Opinion are consistent with the meanings of the same terms in the Legal Opinion and Lawyer's Work Report.
Our lawyers, in accordance with the "Company Law," "Securities Law," "Registration Management Measures," "Securities Legal Business Management Measures," "Securities Legal Business Practice Rules," and other laws, regulations, rules, normative documents, and relevant regulations of the China Securities Regulatory Commission and stock exchanges, and in accordance with the generally accepted business standards, ethical norms, and diligence spirit of the legal profession, hereby issue the following supplementary legal opinion:
I. Approval and Authorization for the Current Issuance
After inspecting the notice of the tenth meeting of the fourth board of directors and the first extraordinary general meeting in 2026, the proposals, resolutions, meeting minutes, and voting slips of the issuer, our lawyers believe that the approval and authorization for the issuer's current issuance remain legal and valid.
II. Subject Qualification of the Issuer for the Current Issuance