Supplementary Legal Opinion (II)
Guangdong Xinda Law Firm on Shenzhen Qiangda Circuit Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Objects
Guangdong Xinda Law Firm (hereinafter referred to as "Xinda") has been entrusted by Shenzhen Qiangda Circuit Co., Ltd. (hereinafter referred to as "Qiangda Circuit," "the issuer," or "the company") to act as the special legal advisor for the company's issuance of convertible bonds to unspecified objects (hereinafter referred to as "this issuance"). Xinda has previously issued the "Lawyer's Work Report" and "Legal Opinion" regarding this issuance.
On March 9, 2026, the Shenzhen Stock Exchange (hereinafter referred to as "SZSE") issued the "Inquiry Letter on Shenzhen Qiangda Circuit Co., Ltd.'s Application for Issuance of Convertible Bonds to Unspecified Objects" (hereinafter referred to as "the Inquiry Letter"). Xinda's lawyers conducted a review of the legal issues raised in the Inquiry Letter that required further verification or explanation by the issuer's lawyers and issued the "Supplementary Legal Opinion (I)" (hereinafter referred to as "Supplementary Legal Opinion (I)").
In accordance with the SZSE's further review opinions and considering that the reporting period for this issuance has been adjusted to the years 2023, 2024, and 2025 (hereinafter referred to as "the reporting period"), Xinda's lawyers conducted supplementary verification of significant changes in legal matters related to the issuance project from October 1, 2025, to December 31, 2025 (hereinafter referred to as "the supplementary verification period") and issued this "Supplementary Legal Opinion (II)" (hereinafter referred to as "this Supplementary Legal Opinion").
Financial Audit and Assurances
The financial statements of the issuer as of December 31, 2025, were audited by Zhonghui and issued the "Audit Report" (Zhonghui Audit [2026] No. 4231) for the fiscal year 2025 (including the years 2022 and 2023) and the "Internal Control Audit Report" (Zhonghui Audit [2026] No. 4232). In the process of issuing this Supplementary Legal Opinion, Xinda has received the following assurances from the company: the company has provided Xinda with all necessary, truthful, complete original written materials, copies, or oral testimonies for the issuance of this Supplementary Legal Opinion, with no concealment, falsehood, or misleading information. The materials provided as copies or reproductions are guaranteed to be consistent with the originals.
Xinda has strictly fulfilled its statutory responsibilities in accordance with the "Securities Law of the People's Republic of China," "Measures for the Administration of Securities Legal Services by Law Firms," and "Trial Implementation Rules for Securities Legal Services by Law Firms," as well as the facts that have occurred or existed prior to the issuance date of this Supplementary Legal Opinion. Xinda has conducted thorough verification and validation, ensuring that the facts recognized in this Supplementary Legal Opinion are true, accurate, and complete. The conclusive opinions expressed in this Supplementary Legal Opinion are legal and accurate, with no false records, misleading statements, or significant omissions, and Xinda assumes corresponding legal responsibilities.
This Supplementary Legal Opinion must be used in conjunction with the "Lawyer's Work Report," "Legal Opinion," and "Supplementary Legal Opinion (I)." The contents of the "Lawyer's Work Report," "Legal Opinion," and "Supplementary Legal Opinion (I)" that have not been modified by this Supplementary Legal Opinion remain valid. The terms, names, and abbreviations used in this Supplementary Legal Opinion, unless otherwise specified, have the same meanings as in the "Lawyer's Work Report" and "Legal Opinion."