Legal Opinion from Beijing Hairun Tianrui Law Firm on Jilin Xidian Pharmaceutical Technology Development Co., Ltd.'s 2026 Restricted Stock Incentive Plan (Draft)

Legal Opinion

Legal Opinion from Beijing Hairun Tianrui Law Firm on Jilin Xidian Pharmaceutical Technology Development Co., Ltd.'s 2026 Restricted Stock Incentive Plan (Draft)

To: Jilin Xidian Pharmaceutical Technology Development Co., Ltd.

Beijing Hairun Tianrui Law Firm (hereinafter referred to as "this Firm") has been entrusted by Jilin Xidian Pharmaceutical Technology Development Co., Ltd. (hereinafter referred to as "Xidian Pharmaceutical," "the Company," or "this Company") to issue a legal opinion regarding the Company's 2026 Restricted Stock Incentive Plan (hereinafter referred to as "this Incentive Plan," "this Plan," or "this Incentive Plan"). This Firm issues this legal opinion based on the relevant laws and regulations, including the Company Law of the People's Republic of China (hereinafter referred to as "the Company Law"), the Securities Law of the People's Republic of China (hereinafter referred to as "the Securities Law"), the Administrative Measures for Equity Incentives of Listed Companies (hereinafter referred to as "the Administrative Measures"), the Listing Rules of the Shenzhen Stock Exchange for the Growth Enterprise Market (hereinafter referred to as "the Listing Rules"), and the Self-Regulatory Guidelines for Listed Companies on the Shenzhen Stock Exchange (hereinafter referred to as "the Regulatory Guidelines").

The lawyers of this Firm declare the following regarding this legal opinion:

1. This Firm and the handling lawyers have strictly fulfilled their statutory duties in accordance with the Securities Law, the Administrative Measures for Securities Legal Services, and the relevant provisions of this legal opinion. They have conducted thorough verification and ensured that the facts recognized in this legal opinion are true, accurate, and complete, and that the conclusions drawn are legal and accurate, with no false records, misleading statements, or significant omissions, and bear corresponding legal responsibilities.

2. Xidian Pharmaceutical has provided a written explanation and commitment that it has supplied this Firm with all necessary original written materials, copies, or oral testimonies required for issuing this legal opinion; that the copies provided are consistent with the original materials; and that the documents and materials provided are complete, true, valid, and contain no concealment, falsehood, or significant omissions. For facts that are crucial to this legal opinion but cannot be supported by independent evidence, this Firm relies on proof documents issued by relevant government departments, Xidian Pharmaceutical, or other relevant units.

3. This legal opinion is solely for the purpose of Xidian Pharmaceutical's use in this Incentive Plan and may not be used for any other purpose without this Firm's consent.

The lawyers of this Firm have verified and validated the relevant documents and facts provided by Xidian Pharmaceutical according to recognized business standards, ethical norms, and the spirit of diligence and responsibility. The legal opinions are as follows:

I. Qualification of Xidian Pharmaceutical to Implement the Incentive Plan

1. Xidian Pharmaceutical currently holds a business license issued by the Jilin City Market Supervision Administration with a unified social credit code of 912202011239483018.

2. Xidian Pharmaceutical is a joint-stock limited company whose shares have been approved for listing on the stock exchange by the State Council's securities regulatory authority, with the stock abbreviation "Xidian Pharmaceutical" and stock code "301130."

3. The Company is legally established and validly existing as a listed company; according to laws, regulations, normative documents, and the Company's articles of association, there are no circumstances requiring termination.