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Supplementary Legal Opinion (Part 1)
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 issuer" or "the company" or "Xinhang New Materials") and, based on the "Lawyer Engagement Contract" signed between the issuer and this firm, serves as the special legal advisor for the issuer's private placement of shares in 2026 (hereinafter referred to as "this issuance"). For this issuance, this firm has issued the "Lawyer Work Report" and "Legal Opinion" on April 20, 2026.
In accordance with the Shenzhen Stock Exchange's "Inquiry Letter on Jiangsu Xinhang New Materials Co., Ltd.'s Application for Private Placement of Shares" issued on May 14, 2026, and relevant laws and regulations such as the "Securities Law of the People's Republic of China" and the "Company Law of the People's Republic of China," this firm provides this supplementary legal opinion regarding the matters requiring legal verification and explanation as requested in the inquiry letter. The definitions, terms, names, and abbreviations used in this supplementary legal opinion, unless otherwise specified, have the same meanings as in the "Legal Opinion" and "Lawyer Work Report." The matters declared by this firm's lawyers in the "Legal Opinion" also apply to this supplementary legal opinion, and the contents of the "Legal Opinion" not modified by this supplementary legal opinion remain valid.
Question 1:
The funds raised from this private placement will not exceed 1 billion RMB, which will be used for the following projects:
- Project 1: Annual production of 8,100 tons of high-performance resins and composites and their supporting engineering construction.
- Project 2: Annual production of 5,000 tons of monomers and their supporting engineering construction.
- Project 3: Construction of a high-performance composite materials innovation center.
During the reporting period, the production and sales of PAEK resins and composites have not yet been realized. Upon reaching full production, Project 1 will add an annual production capacity of 3,000 tons of PAEK (polyaryletherketone) resins and 5,100 tons of composites, with an average annual gross profit margin of 35.72%. Project 2 will increase the existing product capacity, adding an annual production capacity of 5,000 tons of DFBP (4,4-difluorobenzophenone) monomer, with an average annual gross profit margin of 25.04%. Project 3 is a research and development project that will establish a research and testing center related to composite materials.
This project has obtained a filing certificate, with the filing certificate number Ningxin District Management Approval [2026] No. 746, but has not yet obtained environmental and energy assessments. The implementation entities for this fundraising project are all the issuer's holding subsidiary, Nanjing Yilite High Polymer Materials Co., Ltd. (hereinafter referred to as "Yilite"), in which the issuer holds 95% of the shares. The issuer's core management team has established Nanjing Lingfengsong Enterprise Management Partnership (Limited Partnership), and the external technical team has established Tangyuan Lingfengyue Enterprise Management Partnership (Limited Partnership), holding 5% of Yilite's shares.