Grandall Law Firm (Hangzhou) Legal Opinion on the 2026 Restricted Stock Incentive Plan (Draft) of Pujiang Detection Technology (Shanghai) Co., Ltd.
Address: Grandall Building, No.2 & No.15, Block B, Baita Park, Old Fuxing Road, Hangzhou, Zhejiang 310008, China Tel: (+86)(571) 8577 5888 Fax: (+86)(571) 8577 5643 Email: grandallhz@grandall.com.cn Website: http://www.grandall.com.cn June 2026
Table of Contents
- Table of Contents 2
- Definitions 3
- Part I: Introduction 6
- Part II: Main Body 7
- I. Subject Qualifications for the Incentive Plan 7
- II. Main Content of the Incentive Plan 8
- III. Statutory Procedures Involved in the Incentive Plan 19
- IV. Determination and Compliance of Incentive Targets 21
- V. Information Disclosure Related to the Incentive Plan 22
- VI. No Financial Assistance Provided by the Company 22
- VII. Impact of the Incentive Plan on the Company and Shareholders 23
- VIII. Recusal of Interested Directors 23
- IX. Conclusion 23
- Part III: Signature Page 25
Definitions
Unless otherwise specified, the following terms have the specific meanings defined below:
| Term | Definition |
|---|---|
| Company, Pujiang Detection | Pujiang Detection Technology (Shanghai) Co., Ltd. |
| This Incentive Plan | Pujiang Detection Technology (Shanghai) Co., Ltd. 2026 Restricted Stock Incentive Plan |
| Incentive Plan (Draft) | Pujiang Detection Technology (Shanghai) Co., Ltd. 2026 Restricted Stock Incentive Plan (Draft) |
| Assessment Management Measures | Pujiang Detection Technology (Shanghai) Co., Ltd. 2026 Restricted Stock Incentive Plan Implementation Assessment Management Measures |
| Type I Restricted Stock | Company shares obtained by eligible participants under the incentive plan, subject to transfer restrictions as stipulated |
| Type II Restricted Stock | Company shares obtained and registered by eligible participants after meeting corresponding vesting conditions |
| Incentive Targets | Directors, senior management, and key technical/business personnel of the company (including subsidiaries) eligible under this plan |
| Grant Date | The date on which the company grants restricted stock to incentive targets |
| Grant Price | The price at which the company grants each share of restricted stock to incentive targets |
| Validity Period | The period from the initial grant date to the date when all Type I restricted stock is unlocked or repurchased/cancelled, or all Type II restricted stock is vested or invalidated |
| Vesting | The act of the company registering shares to the incentive target's account after vesting conditions are met |
| Vesting Conditions | The benefit conditions set by the incentive plan that targets must meet to obtain incentive shares |
| Vesting Date | The date on which the registration of granted shares is completed after vesting conditions are met |
| CSRC | China Securities Regulatory Commission |
| Term | Definition |
|---|---|
| Stock Exchange | Shenzhen Stock Exchange |
| Company Law | Company Law of the People's Republic of China |
| Securities Law | Securities Law of the People's Republic of China |
| Management Measures | Administrative Measures on Share Incentives of Listed Companies |
| Listing Rules | Rules Governing the Listing of Stocks on the ChiNext Market of the Shenzhen Stock Exchange |
| Self-Regulatory Guidelines No. 1 | Guidelines No. 1 for Self-Regulation of Listed Companies on the ChiNext Market — Business Handling |
| Articles of Association | Articles of Association of Pujiang Detection Technology (Shanghai) Co., Ltd. |
| This Firm | Grandall Law Firm (Hangzhou) |
| Firm Lawyers | The lawyers assigned by this firm for the company's incentive plan |
| Legal Opinion | This Legal Opinion of Grandall Law Firm (Hangzhou) on the 2026 Restricted Stock Incentive Plan (Draft) |
| Yuan, Ten Thousand Yuan | RMB Yuan, RMB Ten Thousand Yuan |