Legal Opinion of Deheng Law Firm on the Third Employee Stock Ownership Plan (Draft) of Hanbo High-tech Materials (Hefei) Co., Ltd.
Definitions
In this "Legal Opinion," unless otherwise specified, the following terms have the meanings set forth below:
- Hanbo High-tech/Company refers to Hanbo High-tech Materials (Hefei) Co., Ltd.
- CSRC refers to the China Securities Regulatory Commission.
- SZSE refers to the Shenzhen Stock Exchange.
- This Firm refers to Deheng Law Firm, Shanghai.
- "Employee Stock Ownership Plan (Draft)" refers to the "Third Employee Stock Ownership Plan (Draft) of Hanbo High-tech Materials (Hefei) Co., Ltd."
- "Management Measures for the Stock Ownership Plan" refers to the "Management Measures for the Third Employee Stock Ownership Plan of Hanbo High-tech Materials (Hefei) Co., Ltd."
- Holders/Participants refer to employees of the company who contribute to the employee stock ownership plan.
- Target Stock refers to the ordinary A-shares of Hanbo High-tech held through legal means in this employee stock ownership plan.
- "Company Law" refers to the "Company Law of the People's Republic of China."
- "Securities Law" refers to the "Securities Law of the People's Republic of China."
- "Guiding Opinions" refers to the "Guiding Opinions on the Pilot Implementation of Employee Stock Ownership Plans by Listed Companies" (Revised 2025).
- "Regulatory Guideline No. 2" refers to the "Self-Regulatory Guidelines No. 2 for Listed Companies on the Shenzhen Stock Exchange—Standardized Operations of Growth Enterprise Market Listed Companies (Revised 2026)."
- "Articles of Association" refers to the current effective "Articles of Association of Hanbo High-tech Materials (Hefei) Co., Ltd." as of the date of this Legal Opinion.
- "Legal Opinion" refers to this "Legal Opinion of Deheng Law Firm on the Third Employee Stock Ownership Plan (Draft) of Hanbo High-tech Materials (Hefei) Co., Ltd."
- China refers to the People's Republic of China, excluding the Hong Kong Special Administrative Region, Macao Special Administrative Region, and Taiwan.
- Laws and regulations refer to the current effective laws and administrative regulations of China as of the date of this Legal Opinion.
- Yuan and Ten Thousand refer to Renminbi Yuan and Ten Thousand Renminbi.
Legal Opinion
Deheng Law Firm has been entrusted by Hanbo High-tech to act as the special legal advisor for this employee stock ownership plan. Based on the Company Law, Securities Law, Guiding Opinions, Regulatory Guideline No. 2, and other relevant laws and regulations, this Firm has issued this Legal Opinion in accordance with recognized business standards and ethical norms in the Chinese legal profession.