Beijing King & Wood (Hangzhou) Law Firm
To: Wankai New Materials Co., Ltd.
This legal opinion is issued by Beijing King & Wood (Hangzhou) Law Firm regarding Wankai New Materials Co., Ltd. (hereinafter referred to as "the Company"). The Company plans to implement the 2026 restricted stock incentive plan (hereinafter referred to as "the Plan"). Based on the relevant laws and regulations of the People's Republic of China (hereinafter referred to as "China"), we provide the following legal opinions regarding the first grant of the Plan.