Legal Opinion
Zhong Lun Law Firm
Special General Partnership Limited Liability Partnership
Beijing Office: 22-24/F & 27-31/F, South Tower of CP Center, 20 Jin He East Avenue, Chaoyang District, Beijing 100020, China
Tel: +86 10 5957 2288 Fax: +86 10 6568 1022/1838 www.zhonglun.com
Beijing Zhong Lun Law Firm
Regarding Shenzhen Jinkeper Technology Co., Ltd.'s 2025 Private Placement of Shares: Issuance Process and Subscriber Compliance Legal Opinion
To: Shenzhen Jinkeper Technology Co., Ltd.
Beijing Zhong Lun Law Firm (hereinafter referred to as the "Firm") is the special legal counsel engaged by Shenzhen Jinkeper Technology Co., Ltd. (hereinafter referred to as the "Company" or "Issuer") for its application for a private placement of shares to specific objects (hereinafter referred to as the "Issuance"). The Firm issued the "Beijing Zhong Lun Law Firm's Legal Opinion on Shenzhen Jinkeper Technology Co., Ltd.'s 2025 Private Placement of Shares" and the "Beijing Zhong Lun Law Firm's Lawyer's Work Report on Shenzhen Jinkeper Technology Co., Ltd.'s 2025 Private Placement of Shares" and other documents (hereinafter collectively referred to as the "Firm's Issued Documents") in December 2025.
The Firm, in accordance with the "Securities Law of the People's Republic of China" (hereinafter referred to as the "Securities Law"), the "Administrative Measures for the Registration of Securities Issuances by Listed Companies" (hereinafter referred to as the "Registration Measures"), the "Administrative Measures for Securities Issuance and Underwriting" (hereinafter referred to as the "Issuance and Underwriting Measures"), the "Implementation Rules for Securities Issuance and Underwriting Business of Listed Companies of Shenzhen Stock Exchange" (hereinafter referred to as the "Implementation Rules"), the "Administrative Measures for Law Firms Engaging in Securities Legal Business," and the "Practice Rules for Securities Legal Business of Law Firms (Trial)" and other currently published and effective laws, regulations, and normative documents, and in accordance with the industry-recognized business standards, ethical norms, and diligent and responsible spirit of lawyers, has conducted on-site verification of the issuance process of the Company's Issuance, inspected and verified relevant documents and facts, and hereby issues this Legal Opinion.
The abbreviations, acronyms, and terms used in this Legal Opinion shall have the same meanings as in the Firm's previously issued documents, unless otherwise specified. The premises and assumptions upon which the Firm's legal opinions were made in the previously issued documents also apply to this Legal Opinion.
The Firm agrees that the Issuer may use this Legal Opinion as a necessary legal document for the Issuer's report on the issuance process, to be submitted to the regulatory authorities for review along with other application materials, and the Firm shall bear the corresponding legal responsibility for the legal opinion issued.
This Legal Opinion is for the sole purpose of the Issuer's report to the regulatory authorities on the issuance process. It may not be used for any other purpose or in any other context without the written permission of the Firm and the handling lawyers.
In accordance with the industry-recognized business standards, ethical norms, and diligent and responsible spirit of lawyers, the Firm's lawyers hereby provide the following legal opinion on the compliance of the issuance process and the subscribers of this Issuance: