Legal Opinion of Beijing Zhonglun Law Firm on the First Extraordinary Shareholders' Meeting of Xinhenghui Electronics Co., Ltd. in 2026

Beijing Zhonglun Law Firm (hereinafter referred to as "this Firm") has been entrusted by Xinhenghui Electronics Co., Ltd. (hereinafter referred to as "the Company") to issue this legal opinion regarding the Company's first extraordinary shareholders' meeting in 2026 (hereinafter referred to as "this Meeting"). This opinion is based on the "Company Law of the People's Republic of China," "Securities Law of the People's Republic of China," "Rules for Shareholders' Meetings of Listed Companies," "Listing Rules for the Growth Enterprise Market of Shenzhen Stock Exchange," and other relevant laws, regulations, and normative documents, as well as the currently effective "Articles of Association of Xinhenghui Electronics Co., Ltd." (hereinafter referred to as "the Articles of Association"). This legal opinion only addresses the legality of the convening and holding procedures of this Meeting, the qualifications of attendees, the qualifications of the convener, the voting procedures, and the voting results, and does not express opinions on the content of the proposals reviewed at this meeting or the truthfulness and accuracy of the facts or data presented in those proposals. The lawyers of this Firm assume that all materials submitted to them by the Company (including but not limited to the identity cards of relevant personnel, power of attorney, business license, shareholder register, online voting results, etc.) are true, accurate, and complete; that the signatures and seals on such materials are genuine; that the signatories have full civil capacity; and that their signing actions have been properly and effectively authorized or have followed necessary legal procedures; and that copies or reproductions of such materials are consistent with the originals. This legal opinion is only for the purpose of witnessing the legality of matters related to this Meeting and may not be used for any other purpose without the prior consent of this Firm's lawyers. The lawyers of this Firm agree to disclose this legal opinion along with the Company's relevant announcements regarding this Meeting and assume corresponding legal responsibilities. To issue this legal opinion, the lawyers of this Firm conducted necessary verifications of the relevant documents and other matters related to this Meeting. Based on the verification work, the lawyers of this Firm issue the following legal opinions in accordance with the recognized business standards, ethical norms, and diligence spirit of the Chinese legal profession: