Beijing Jin Du (Shenzhen) Law Firm Legal Opinion on the First Extraordinary Shareholders' Meeting of Shenzhen Min Explosive Optoelectronics Co., Ltd. in 2026
To: Shenzhen Min Explosive Optoelectronics Co., Ltd.
Beijing Jin Du (Shenzhen) Law Firm (hereinafter referred to as "this firm") has been entrusted by Shenzhen Min Explosive Optoelectronics Co., Ltd. (hereinafter referred to as "the Company") to issue this legal opinion in accordance with the Securities Law of the People's Republic of China (hereinafter referred to as "Securities Law"), the Company Law of the People's Republic of China (hereinafter referred to as "Company Law"), and the Rules for Shareholders' Meetings of Listed Companies issued by the China Securities Regulatory Commission (hereinafter referred to as "Shareholders' Meeting Rules"), as well as other applicable laws, administrative regulations, rules, and normative documents currently in effect within the territory of the People's Republic of China (hereinafter referred to as "China"), excluding the Hong Kong Special Administrative Region, Macao Special Administrative Region, and Taiwan Province for the purposes of this legal opinion. This firm appointed lawyers to attend the first extraordinary shareholders' meeting of the Company held on February 26, 2026 (hereinafter referred to as "this meeting") and issued this legal opinion regarding the relevant matters of this meeting.
To issue this legal opinion, the lawyers of this firm reviewed the following documents provided by the Company, including but not limited to:
- The Articles of Association of the Company approved at the Company's second extraordinary shareholders' meeting in 2025;
- The announcement of the resolution of the seventh meeting of the third board of directors of the Company published on February 11, 2026, on the Giant Tide Information Network and the Shenzhen Stock Exchange website;
- The notice of the first extraordinary shareholders' meeting of 2026 published on February 11, 2026, on the Giant Tide Information Network and the Shenzhen Stock Exchange website (hereinafter referred to as "Meeting Notice");
- The shareholder register as of the record date for this meeting;
- The attendance registration records and supporting materials of shareholders present at the meeting;
- The statistical results of the online voting for this meeting provided by Shenzhen Securities Information Co., Ltd.;
- The relevant proposals and announcements related to this meeting;
- Other meeting documents for this meeting.
The Company has assured this firm that it has disclosed all facts that could affect the issuance of this legal opinion and provided all 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 to this firm are true, accurate, complete, and valid, and if the documents are copies or reproductions, they are consistent with the originals.
In this legal opinion, this firm only expresses opinions on the procedures for convening and holding this meeting, the qualifications of the attendees, the qualifications of the convener, and whether the voting procedures and results comply with relevant laws, administrative regulations, the Shareholders' Meeting Rules, and the Articles of Association. This firm does not express opinions on the content of the proposals reviewed at this meeting or the truthfulness and accuracy of the facts or data stated in those proposals. This firm only expresses opinions based on the currently effective laws and regulations within China and does not express opinions based on any laws outside of China.