Beijing Zhong Yin Law Firm
Supplementary Legal Opinion (II) (Revised Draft)
Regarding Guangdong Siquan New Materials Co., Ltd.'s 2025 Private Placement of Shares
(Revised Draft)
To: Guangdong Siquan New Materials Co., Ltd.
Beijing Zhong Yin Law Firm (hereinafter referred to as "Zhong Yin" or "the Firm") has been engaged by Guangdong Siquan New Materials Co., Ltd. (hereinafter referred to as "the Issuer") as special legal counsel for the Issuer's 2025 private placement of shares (hereinafter referred to as "this Offering"). Zhong Yin has, in accordance with the Securities Law, the Company Law, the Administrative Measures for the Registration of Securities Offerings, the Administrative Measures for Law Firms Engaging in Securities Legal Business, the Practice Rules for Law Firms Engaging in Securities Legal Business (Trial), and the Disclosure Rules for Public Offerings of Securities No. 12 — Legal Opinions and Lawyers' Reports on Public Offerings of Securities, as well as relevant regulations of the China Securities Regulatory Commission (CSRC), and in accordance with the generally accepted business standards, ethical norms, and the spirit of diligence and conscientiousness of the legal profession, issued the "Legal Opinion of Beijing Zhong Yin Law Firm on Guangdong Siquan New Materials Co., Ltd.'s 2025 Private Placement of Shares," the "Lawyers' Work Report of Beijing Zhong Yin Law Firm on Guangdong Siquan New Materials Co., Ltd.'s 2025 Private Placement of Shares," the "Supplementary Legal Opinion (I) of Beijing Zhong Yin Law Firm on Guangdong Siquan New Materials Co., Ltd.'s 2025 Private Placement of Shares," the "Supplementary Legal Opinion (II) of Beijing Zhong Yin Law Firm on Guangdong Siquan New Materials Co., Ltd.'s 2025 Private Placement of Shares," and the "Supplementary Legal Opinion (III) of Beijing Zhong Yin Law Firm on Guangdong Siquan New Materials Co., Ltd.'s 2025 Private Placement of Shares" (collectively referred to as "the previously issued legal documents").
The Listing Review Center of the Shenzhen Stock Exchange issued the "Second Round of Review Inquiry Letter" (No. [2025] 020070) on November 14, 2025, posing questions regarding this Offering. Additionally, the Issuer disclosed the "Guangdong Siquan New Materials Co., Ltd. Third Quarterly Report 2025" (hereinafter referred to as the "2025 Third Quarterly Report") on October 30, 2025. Due to changes in the Issuer's situation from July 1, 2025, to September 30, 2025, the reporting period has been updated to September 30, 2025 (July 1, 2025, to September 30, 2025, is hereinafter referred to as the "Supplementary Reporting Period," and the Issuer's financial statements for January-September 2025 (unaudited) are hereinafter referred to as the "Latest Financial Statements").
The Firm has issued the "Supplementary Legal Opinion (II) of Beijing Zhong Yin Law Firm on Guangdong Siquan New Materials Co., Ltd.'s 2025 Private Placement of Shares" to address the issues requiring legal opinion in the "Second Round of Review Inquiry Letter" and the updated reporting period. Furthermore, the "Supplementary Legal Opinion (III) of Beijing Zhong Yin Law Firm on Guangdong Siquan New Materials Co., Ltd.'s 2025 Private Placement of Shares" has been issued to provide updated legal opinions on the matters raised in the "Second Round of Review Inquiry Letter." This document, "Supplementary Legal Opinion (II) of Beijing Zhong Yin Law Firm on Guangdong Siquan New Materials Co., Ltd.'s 2025 Private Placement of Shares (Revised Draft)" (hereinafter referred to as "this Supplementary Legal Opinion"), is hereby reissued to reflect the updated reporting period.
This Supplementary Legal Opinion supplements the previously issued legal documents and forms an integral part thereof. In case of any inconsistency between the previously issued legal documents and this Supplementary Legal Opinion, this Supplementary Legal Opinion shall prevail. The declarations made in the previously issued legal documents by Zhong Yin Lawyers shall also apply to this Supplementary Legal Opinion. Unless otherwise specified, the definitions, terms, and abbreviations used in this Supplementary Legal Opinion are consistent with those in the previously issued legal documents. For content that has not changed from the previously issued legal documents, this Supplementary Legal Opinion will not reiterate the legal opinions.