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Beijing Dentons (Shanghai) Law Office
Regarding
Huibo New Material Technology (Shanghai) Co., Ltd.
2026 Restricted Stock Incentive Plan (Draft)
Legal Opinion
9th/24th/25th Floor, Shanghai World Financial Center, 100 Century Avenue, Shanghai 200120, P. R. China
Tel: +86 21-58785888 Fax: +86 21-58786866
Table of Contents
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Definitions
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Main Text
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I. Conditions for the Company to Implement this Incentive Plan
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II. Content of this Incentive Plan
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III. Procedures for Drafting, Reviewing, and Publicizing this Incentive Plan
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IV. Determination of Incentive Targets
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V. Information Disclosure of this Incentive Plan
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VI. Funding Sources for Incentive Targets to Participate in this Incentive Plan
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VII. Impact of this Incentive Plan on the Company and the Interests of All Shareholders
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VIII. Circumstances of Interested Directors Recusing Themselves from Voting
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IX. Conclusion
Definitions
In this legal opinion, unless the context otherwise requires, the following abbreviations and terms have the following meanings:
| Term | Definition |
|---|---|
| This Office, Our Lawyers | Beijing Dentons (Shanghai) Law Office or its lawyers |
| Company, Huibo New Material | Huibo New Material Technology (Shanghai) Co., Ltd. (including holding subsidiaries) |
| This Incentive Plan | Huibo New Material Technology (Shanghai) Co., Ltd. 2026 Restricted Stock Incentive Plan |
| Restricted Stock | Company shares obtained and registered in batches by incentive targets who meet the grant conditions of this Incentive Plan, after satisfying the corresponding vesting conditions |
| Incentive Targets | Directors, senior management, core technical personnel, and core key employees of the Company who obtain restricted stock in accordance with the provisions of this Incentive Plan |
| Grant Date | The date on which the Company grants restricted stock to the incentive targets |
| Grant Price | The price at which the Company grants each share of restricted stock to the incentive targets |
| Validity Period | The period from the date of the restricted stock grant until all restricted stock granted to the incentive targets is vested or invalidated |
| Vesting | The act of the Company registering shares to the incentive target's account after the incentive target meets the benefit conditions |
| Vesting Conditions | The benefit conditions that the incentive target must meet to obtain restricted stock |
| Incentive Plan (Draft) | Huibo New Material Technology (Shanghai) Co., Ltd. 2026 Restricted Stock Incentive Plan (Draft) |
| Assessment Management Measures | Huibo New Material Technology (Shanghai) Co., Ltd. 2026 Restricted Stock Incentive Plan Implementation Assessment Management Measures |
| Lixin | Lixin Certified Public Accountants (Special General Partnership) |
| Remuneration and Appraisal Committee | The Remuneration and Appraisal Committee of the Board of Directors of Huibo New Material Technology (Shanghai) Co., Ltd. |
| CSRC | China Securities Regulatory Commission |
| SZSE | Shenzhen Stock Exchange |
| Articles of Association | Articles of Association of Huibo New Material Technology (Shanghai) Co., Ltd. |
| Company Law | Company Law of the People's Republic of China (2023 Revision) |
| Securities Law | Securities Law of the People's Republic of China (2019 Revision) |
| Administrative Measures | Administrative Measures on Equity Incentives of Listed Companies (2025 Amendment) |
| Listing Rules | Rules Governing the Listing of Stocks on the ChiNext Market of the Shenzhen Stock Exchange (2026 Revision) |
| Self-Regulatory Guidelines | Shenzhen Stock Exchange ChiNext Listed Company Self-Regulatory Guidelines No. 1 — Business Handling |
| Securities Legal Business Management Measures | Administrative Measures for Law Firms Engaging in Securities Legal Business |
| Securities Legal Business Practice Rules | Practice Rules for Law Firms in Securities Legal Business (Trial) |
| China | People's Republic of China |
| Chinese Laws | Relevant laws, regulations, and normative documents publicly promulgated and implemented by legislative bodies and competent departments within the People's Republic of China |
| Yuan (Ten Thousand Yuan) | Renminbi Yuan (Renminbi Ten Thousand Yuan) |