Legal Opinion from AllBright Law Offices
To: Liaoning Xinde New Materials Technology (Group) Co., Ltd.
AllBright Law Offices (hereinafter referred to as "this firm") has been entrusted by Liaoning Xinde New Materials Technology (Group) Co., Ltd. (hereinafter referred to as "the Company") to issue this legal opinion regarding the second extraordinary shareholders' meeting (hereinafter referred to as "the Meeting") held on February 25, 2026, in accordance with the Company Law of the People's Republic of China (hereinafter referred to as "the Company Law"), the Securities Law of the People's Republic of China (hereinafter referred to as "the Securities Law"), the Rules for Shareholders' Meetings of Listed Companies issued by the China Securities Regulatory Commission (hereinafter referred to as "the Meeting Rules"), and other relevant laws, regulations, and normative documents, as well as the Articles of Association of Liaoning Xinde New Materials Technology (Group) Co., Ltd. (hereinafter referred to as "the Articles of Association").
Lawyers from this firm attended the Meeting and issued this legal opinion regarding the relevant matters of the Meeting. To issue this legal opinion, the lawyers of this firm reviewed the relevant matters involved in the Meeting, examined the related meeting documents, and conducted necessary verifications. The Company has assured this firm that it has disclosed all facts that could affect the issuance of this legal opinion and provided the original written materials, copies, letters of commitment, or certificates required by this firm for the issuance of this legal opinion, with no concealment, false statements, or significant omissions; the documents and materials provided by the Company are true, accurate, complete, and valid, and the copies or duplicates are consistent with the originals.
In this legal opinion, this firm expresses opinions solely based on the currently effective laws and regulations regarding the convening and holding procedures of the Meeting, the qualifications of attendees, the qualifications of the convener, and whether the voting procedures and results comply with relevant laws, regulations, the Meeting Rules, and the Articles of Association, without commenting on the content of the proposals reviewed at the Meeting or the truthfulness and accuracy of the facts or data expressed in such proposals. This firm has strictly fulfilled its statutory responsibilities, adhered to the principles of diligence and good faith, and conducted thorough verification of the relevant matters of the Meeting, ensuring that the facts recognized in this legal opinion are true, accurate, and complete, and that the conclusive opinions expressed in this legal opinion are lawful and accurate, with no false records, misleading statements, or significant omissions, and assumes corresponding legal responsibilities.
This firm agrees to use this legal opinion as part of the announcement materials for the Meeting, to be submitted along with other meeting documents to relevant institutions and announced. Furthermore, without the consent of this firm, this legal opinion shall not be used by any other person for any other purpose.