King & Wood Mallesons Legal Opinion on the Issuance of Shares for Asset Acquisition and Related Party Transactions of Shenzhen Minbao Optoelectronics Co., Ltd.

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Regarding

Shenzhen Minbao Optoelectronics Co., Ltd.

Issuance of Shares for Asset Acquisition and Related Party Transactions

Legal Opinion

July 2026

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Table of Contents

Introduction 4

Definitions 6

Main Text 8

Part I: Plan for the Current Transaction 8

1. Overall Plan for the Current Transaction 8

2. Issuance of Shares for Asset Acquisition 8

3. Nature of the Current Transaction 15

Part II: Subject Qualifications of the Parties to the Current Transaction 16

1. Listed Company 16

2. Counterparties 19

Part III: Approvals and Authorizations for the Current Transaction 20

1. Approvals and Authorizations Already Obtained 20

2. Approvals and Authorizations Still Required 20

Part IV: Relevant Agreements for the Current Transaction 21

1. "Agreement on Issuance of Shares for Asset Acquisition" and "Supplementary Agreement to the Agreement on Issuance of Shares for Asset Acquisition" 21

2. "Performance Compensation Agreement" 21

Part V: Target Assets Involved in the Current Transaction 21

1. Basic Information and Equity Structure of the Target Company 21

2. Equity Changes Since the Establishment of the Target Company 23

3. Main Assets of the Target Company 25

4. Main Business and Qualifications of the Target Company 29

5. Taxation of the Target Company 30

6. Product Quality, Environmental Protection, and Labor Protection of the Target Company 32

7. Major Litigation, Arbitration, and Administrative Penalties 32

Part VI: Handling of Creditor's Rights and Debts in the Current Transaction 33

Part VII: Related Party Transactions and Horizontal Competition 33

1. Related Party Transactions 33

2. Horizontal Competition 34

Part VIII: Information Disclosure by the Listed Company Regarding the Current Transaction 35

Part IX: Substantive Conditions for the Current Transaction 35

1. Compliance with Relevant Provisions of the "Company Law" 36

2. Compliance with Relevant Provisions of the "Securities Law" 36

3. Compliance with Relevant Provisions of the "Administrative Measures for Restructuring" 36

4. Compliance with Relevant Provisions of the "Administrative Measures for Issuance Registration" 40

Part X: Securities Service Institutions Engaged by the Listed Company for the Current Transaction 41

Part XI: Self-Inspection of Stock Trading by Relevant Parties to the Current Transaction 42

Part XII: Verification of Key Audit Points for the Current Transaction 42

Part XIII: Conclusion 55

Appendix: List of Intellectual Property Rights 57

Introduction

To: Shenzhen Minbao Optoelectronics Co., Ltd.

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 "Administrative Measures for Major Asset Restructuring of Listed Companies" (hereinafter referred to as the "Administrative Measures for Restructuring"), the "Guidelines for Supervision of Listed Companies No. 9 — Regulatory Requirements for Planning and Implementing Major Asset Restructuring by Listed Companies" (hereinafter referred to as "Regulatory Guidelines No. 9"), and other laws, administrative regulations, departmental rules, normative documents, relevant rules of the Shenzhen Stock Exchange (hereinafter referred to as the "SZSE") (collectively referred to as "Relevant Provisions"), and the "Articles of Association of Shenzhen Minbao Optoelectronics Co., Ltd.", King & Wood Mallesons (hereinafter referred to as "this Firm") has been engaged by Shenzhen Minbao Optoelectronics Co., Ltd. (hereinafter referred to as "Minbao Optoelectronics" or the "Listed Company") to issue this legal opinion regarding the matters related to the Listed Company's issuance of shares for asset acquisition and related party transactions (hereinafter referred to as the "Current Transaction").