Beijing Deheng Law Offices
Supplementary Legal Opinion (I) (Revised Draft) on Tianjin Guoxuan Mengguli New Material Technology Co., Ltd.'s 2025 Issuance of Shares to Specific Targets
To: Tianjin Guoxuan Mengguli New Material Technology Co., Ltd.
Deheng Ref. No. 11F20260021-07
Our firm was retained by the issuer as its special legal counsel for the issuer's 2025 issuance of shares to specific targets. Pursuant to the relevant provisions of the Securities Law, the Company Law, the "Norms for the Preparation of Information Disclosure by Issuers of Publicly Issued Securities (No. 12) — Legal Opinions and Lawyer's Work Reports on Publicly Issued Securities," the "Administrative Measures for Law Firms Engaging in Securities Legal Business" (Order No. 223 of the China Securities Regulatory Commission and the Ministry of Justice of the People's Republic of China), and the "Practice Rules for Securities Legal Business of Law Firms (Trial)" (Announcement No. 33 of the China Securities Regulatory Commission and the Ministry of Justice of the People's Republic of China), and in accordance with the business standards, ethical norms, and diligent and conscientious spirit generally accepted in the legal profession, we issued the "Legal Opinion of Beijing Deheng Law Offices on Tianjin Guoxuan Mengguli New Material Technology Co., Ltd.'s 2025 Issuance of Shares to Specific Targets" (hereinafter referred to as the "Legal Opinion"), the "Lawyer's Work Report of Beijing Deheng Law Offices on Tianjin Guoxuan Mengguli New Material Technology Co., Ltd.'s 2025 Issuance of Shares to Specific Targets," and other necessary verification opinions on April 23, 2026. On June 8, 2026, we issued the "Supplementary Legal Opinion (I) of Beijing Deheng Law Offices on Tianjin Guoxuan Mengguli New Material Technology Co., Ltd.'s 2025 Issuance of Shares to Specific Targets" (hereinafter referred to as "Supplementary Legal Opinion (I)").
On May 20, 2026, the Shenzhen Stock Exchange issued the "Inquiry Letter on the Application for Issuance of Shares to Specific Targets by Tianjin Guoxuan Mengguli New Material Technology Co., Ltd." (Inquiry Letter [2026] No. 020046) (hereinafter referred to as the "Inquiry Letter") to the issuer, requesting the issuer and relevant intermediaries to provide explanations, conduct investigations, and issue opinions. In accordance with the requirements of the "Inquiry Letter" and the further review opinions of the Shenzhen Stock Exchange, our firm has investigated and updated the issues that require the issuer's lawyers to investigate and provide explicit opinions. We hereby issue the "Supplementary Legal Opinion (I) (Revised Draft) of Beijing Deheng Law Offices on Tianjin Guoxuan Mengguli New Material Technology Co., Ltd.'s 2025 Issuance of Shares to Specific Targets." This supplementary legal opinion has revised and bolded the modifications to "Supplementary Legal Opinion (I)" in bold italics.
For the purpose of issuing this supplementary legal opinion, our firm has conducted supplementary investigations into the relevant facts and materials based on the facts relied upon in the "Legal Opinion" and the "Lawyer's Work Report," in accordance with the provisions of relevant Chinese laws, regulations, and normative documents.
This supplementary legal opinion supplements the "Legal Opinion" and the "Lawyer's Work Report" and forms an integral part thereof. The statements made in the "Legal Opinion" and the "Lawyer's Work Report" apply to this supplementary legal opinion. Unless otherwise specified, the terms, names, and abbreviations used in this supplementary legal opinion have the same meanings as those in the "Legal Opinion" and the "Lawyer's Work Report" issued by our firm.
Our firm agrees that this supplementary legal opinion will be used as a necessary legal document for the issuer's current issuance and will be submitted together with other application materials. We guarantee the truthfulness, accuracy, and completeness of this supplementary legal opinion.