Supplementary Legal Opinion from Beijing Junhe Law Firm on Zhonglun New Materials Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Objects (II)
To: Zhonglun New Materials Co., Ltd.
Beijing Junhe Law Firm has been entrusted by Zhonglun New Materials Co., Ltd. to appoint our lawyers as specially invited legal advisors. On October 27, 2025, we issued the "Lawyer's Work Report on Zhonglun New Materials Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Objects" (hereinafter referred to as the "Lawyer's Work Report") and the "Legal Opinion on Zhonglun New Materials Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Objects" (hereinafter referred to as the "Legal Opinion"). On December 2, 2025, we issued the "Supplementary Legal Opinion (I)" (hereinafter referred to as "Supplementary Legal Opinion (I)"), which, along with the Lawyer's Work Report and the Legal Opinion, is collectively referred to as the "Issued Legal Documents."
We now provide the "Supplementary Legal Opinion (II)" (hereinafter referred to as "this Supplementary Legal Opinion") regarding the relevant legal matters related to the changes in the issuer's production and operational activities from October 1, 2025, to December 31, 2025. This Supplementary Legal Opinion serves as a supplement to the Issued Legal Documents and constitutes an inseparable part of them. Unless otherwise specified, the premises and assumptions under which we expressed legal opinions in the Issued Legal Documents also apply to this Supplementary Legal Opinion. For matters described in this Supplementary Legal Opinion, the explanations herein shall prevail. Unless the context indicates otherwise, the abbreviations used in this Supplementary Legal Opinion have the same meanings as those in the Issued Legal Documents.
To issue this Supplementary Legal Opinion, our lawyers conducted a legal due diligence investigation based on the requirements of Chinese laws, regulations, and normative documents, as well as the issuer's entrustment. We reviewed the documents and materials deemed necessary for issuing this Supplementary Legal Opinion and relevant laws, regulations, and normative documents. We also inquired with relevant personnel of the issuer and engaged in necessary discussions, employing reasonable and sufficient methods including but not limited to on-site investigations, face-to-face interviews, written reviews, and inquiries to verify and confirm relevant facts. Based on our understanding of the facts and legal interpretations, we express legal opinions on facts that have occurred and existed prior to the issuance date of this Supplementary Legal Opinion.
During the due diligence process, we received the following written assurances from the issuer: the issuer has provided original written materials, copies, or oral testimonies necessary for our issuance of this Supplementary Legal Opinion; the documents and facts provided to us are true, accurate, and complete, with no omissions or concealments; the copies or reproductions provided are entirely consistent with the original documents, and the signatures and seals on the documents are genuine and valid. The validity of the originals or originals has not been revoked by relevant government departments during their effective period, and they are held by their respective legal holders as of the issuance date of this Supplementary Legal Opinion.
For facts that are crucial for issuing this Supplementary Legal Opinion but cannot be supported by independent evidence, we rely on the certification documents or written statements issued by relevant government departments, the issuer, or other relevant institutions or units to make judgments. Our lawyers only express opinions on legal issues related to this issuance and do so solely based on Chinese law, without commenting on accounting, auditing, capital verification, asset evaluation, rating, business judgment, investment decisions, or foreign laws.