Legal Opinion from Allbright Law Offices
Address: 11th and 12th Floors, Shanghai Center Building, 501 Yincheng Middle Road, Pudong New District, Shanghai
Phone: 021-20511000; Fax: 021-20511999
Postal Code: 200120
To: Jiangsu Xinhang New Materials Co., Ltd.
Allbright Law Offices (hereinafter referred to as "this firm") has been entrusted by Jiangsu Xinhang New Materials Co., Ltd. (hereinafter referred to as "the Company") to provide a legal opinion regarding the Company's first extraordinary shareholders' meeting of 2026 (hereinafter referred to as "this meeting"). This opinion is issued in accordance with the Company Law of the People's Republic of China (hereinafter referred to as "the Company Law"), the Rules for Shareholders' Meetings of Listed Companies, and other relevant laws, regulations, and normative documents, as well as the provisions of the Articles of Association of Jiangsu Xinhang New Materials Co., Ltd. (hereinafter referred to as "the Articles of Association").
To issue this legal opinion, this firm and its lawyers have strictly fulfilled their statutory duties in accordance with the Administrative Measures for Securities Legal Services by Law Firms and the Practice Rules for Securities Legal Services (Trial), adhering to the principles of diligence and good faith. Necessary verifications and checks have been conducted regarding the matters involved in this meeting, and relevant documents and materials deemed necessary for issuing this legal opinion have been reviewed. The lawyers of this firm participated in the entire process of this meeting. This firm guarantees that the facts determined in this legal opinion are true, accurate, and complete, and that the conclusions expressed are legal and accurate, with no false records, misleading statements, or significant omissions, and is willing to bear corresponding legal responsibilities.
In view of the above, the lawyers of this firm provide the following legal opinions based on the requirements of the aforementioned laws, regulations, rules, and normative documents, in accordance with the recognized business standards, ethical norms, and spirit of diligence in the legal profession:
- The qualifications of the convener and the procedures for convening and holding this meeting have been verified. This meeting was convened by the Company's board of directors. The board of directors published the "Notice of the First Extraordinary Shareholders' Meeting of Jiangsu Xinhang New Materials Co., Ltd." on February 11, 2026, on the information disclosure website designated by the China Securities Regulatory Commission, announcing the meeting time, equity registration date, location of the on-site meeting, convener, meeting method, matters for deliberation, attendees, registration matters, specific procedures for participating in online voting, contact information, and other matters. The notice was published 15 days prior to the meeting date. This meeting was held using a combination of on-site voting and online voting. Specifically, the on-site meeting was held at 14:30 on February 26, 2026, in the conference room on the fourth floor of Building A1, No. 86, Tank Area South Road, Nanjing Chemical Industry Park, Jiangsu Province. The online voting time was on February 26, 2026, during which the voting time through the Shenzhen Stock Exchange trading system was from 9:15 to 9:25, 9:30 to 11:30, and 13:00 to 15:00; the specific time for voting through the Shenzhen Stock Exchange Internet voting system was any time from 9:15 to 15:00 on February 26, 2026. After verification, the lawyers of this firm believe that the qualifications of the convener for this meeting are legal and valid, and the Company published the meeting notice 15 days prior to the meeting, with the timing, method, and content of the notice complying with the provisions of laws, regulations, normative documents, and the Articles of Association. The time, location, and content of the on-site meeting are consistent with the notice, and the online voting time complies with the notice content. The convening and holding of this meeting comply with the provisions of laws, regulations, and the Articles of Association.