[Image: Kangda Law Firm Logo]
Beijing Kangda Law Firm
Regarding
Foshan Blue Rocket Electronics Co., Ltd.
2026 Restricted Stock Incentive Plan (Draft)
Legal Opinion
Kangda Law Opinion [2026] No. 0350
August 2026
Table of Contents
Definitions 2
Main Text 6
I. Eligibility of the Company to Implement the Incentive Plan 6
II. Legality and Compliance of the Main Contents of the Incentive Plan 7
III. Statutory Procedures to be Performed for the Incentive Plan 9
IV. Determination of Incentive Participants 10
V. Information Disclosure of the Incentive Plan 11
VI. Verification of Whether the Company Provides Financial Assistance to Incentive Participants 11
VII. Verification of Whether the Content of the Incentive Plan Significantly Harms the Interests of the Listed Company and All Shareholders or Violates Relevant Laws and Administrative Regulations 11
VIII. Verification of Whether Interested Directors of the Company Have Performed Their Recusal Obligations 12
IX. Concluding Opinion 12
Definitions
In this Legal Opinion, unless the context otherwise requires, the following terms or abbreviations have the following meanings:
| Abbreviation | Meaning |
|---|---|
| The Firm | Beijing Kangda Law Firm |
| Blue Rocket Electronics / Listed Company / Company | Foshan Blue Rocket Electronics Co., Ltd. |
| This Incentive Plan / The Incentive Plan / The Plan | Foshan Blue Rocket Electronics Co., Ltd. 2026 Restricted Stock Incentive Plan |
| Incentive Plan (Draft) | Foshan Blue Rocket Electronics Co., Ltd. 2026 Restricted Stock Incentive Plan (Draft) |
| Assessment Management Measures | Foshan Blue Rocket Electronics Co., Ltd. 2026 Restricted Stock Incentive Plan Implementation Assessment Management Measures |
| Restricted Stock, Type II Restricted Stock | Company shares obtained and registered in batches by eligible incentive participants after meeting corresponding benefit conditions |
| Incentive Participant | Personnel granted restricted stock in accordance with this plan |
| Grant Date | The date on which the company grants restricted stock to incentive participants; the grant date must be a trading day |
| Grant Price | The price of each share of restricted stock granted to incentive participants as determined by this plan |
| Validity Period | From the initial grant date until the date when all restricted stock granted to incentive participants is vested or becomes invalid |
| Vesting | The act of the listed company registering shares to the incentive participant's account after the participant meets the benefit conditions |
| Vesting Conditions | The conditions set by this incentive plan that must be met for incentive participants to obtain incentive shares |
| Audit Report | Foshan Blue Rocket Electronics Co., Ltd. Audit Report (Huaxing Shenzi [2026] No. 25015370010) |
| Company Law | Company Law of the People's Republic of China |
| Securities Law | Securities Law of the People's Republic of China |
| Administrative Measures | Administrative Measures on Equity Incentives of Listed Companies (2025 Revision) |
| Listing Rules | Shenzhen Stock Exchange GEM Stock Listing Rules (2026 Revision) |
| Self-Regulatory Guidelines No. 1 | Shenzhen Stock Exchange GEM Listed Company Self-Regulatory Guidelines No. 1 - Business Handling (2026 Revision) |
| Articles of Association | Articles of Association of Foshan Blue Rocket Electronics Co., Ltd. |
| CSRC | China Securities Regulatory Commission |
| SZSE | Shenzhen Stock Exchange |
| Yuan | Renminbi Yuan |
To: Foshan Blue Rocket Electronics Co., Ltd.
This firm has been engaged by Blue Rocket Electronics to serve as the special legal counsel for the company's implementation of this incentive plan. Based on the examination of relevant materials provided by the issuer, and in accordance with the Company Law, Securities Law, Administrative Measures, Listing Rules, Self-Regulatory Guidelines No. 1, Administrative Measures for Law Firms Engaging in Securities Legal Business, and the Practice Rules for Law Firms Engaging in Securities Legal Business (Trial), and other current laws, administrative regulations, rules, and relevant provisions, we have issued this Legal Opinion in accordance with recognized business standards, ethical norms, and the spirit of diligence and responsibility of the legal profession.