Grandall Law Firm (Shanghai)
Legal Opinion on the Special Verification of Strategic Investors for the Initial Public Offering and ChiNext Listing of Suzhou Betely Polymer Material Co., Ltd.
To: Guosen Securities Co., Ltd.
Grandall Law Firm (Shanghai) (hereinafter referred to as "this Firm") was engaged by Guosen Securities Co., Ltd. (hereinafter referred to as "Guosen Securities," "Sponsor," or "Lead Underwriter") to conduct a verification and issue this legal opinion regarding the strategic placement (hereinafter referred to as "this Placement") for the initial public offering and listing on the ChiNext market (hereinafter referred to as "this Offering") of Suzhou Betely Polymer Material Co., Ltd. (hereinafter referred to as "Betely" or "Issuer").
In accordance with the Securities Law of the People's Republic of China, the Administrative Measures for the Issuance and Underwriting of Securities, the Administrative Measures for the Registration of Initial Public Offering of Shares, the Implementation Rules for the Initial Public Offering and Underwriting Business of the Shenzhen Stock Exchange (2026 Revision), and the Rules for the Underwriting Business of Initial Public Offering of Securities, and following professional standards, ethical norms, and the principle of due diligence, this Firm has verified the selection criteria, qualification for placement, and prohibited circumstances regarding the strategic investors participating in this Offering and hereby issues this legal opinion.
Statement
For the purpose of issuing this legal opinion, this Firm makes the following statements:
(1) This Firm and its handling lawyers have strictly performed their statutory duties and followed the principles of due diligence and good faith in conducting sufficient verification based on the aforementioned laws, regulations, and facts existing prior to the date of this legal opinion.
(2) This Firm expresses its legal opinion based on facts existing prior to the date of this legal opinion and in accordance with current Chinese laws, regulations, and relevant provisions of the China Securities Regulatory Commission (CSRC) and the Shenzhen Stock Exchange.
(3) This Firm has reviewed the originals, copies, or duplicates of documents provided by Guosen Securities and Betely relevant to this legal opinion and has conducted necessary verification. Guosen Securities and Betely have guaranteed to this Firm that all legal documents and materials provided (including but not limited to original written materials, copies, or oral testimony) are complete, true, and valid, and that all facts have been disclosed to this Firm without any concealment, omission, falsehood, or misleading information. The copies or duplicates provided are consistent with the originals, the signatures and seals are authentic, and the signatories have been legally authorized to sign such documents.
(4) This legal opinion is intended solely for the purpose of the Issuer's strategic placement and shall not be used for any other purpose.
I. Basic Information of Strategic Investors
According to the "Strategic Placement Plan for the Initial Public Offering and ChiNext Listing of Suzhou Betely Polymer Material Co., Ltd." and the placement agreements signed between the strategic investors and the Issuer, the selection of investors participating in the strategic placement was determined based on investor qualifications and market conditions, including the following three categories:
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Relevant subsidiaries of the Sponsor (if any): Guosen Capital Co., Ltd. (hereinafter referred to as "Guosen Capital").
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Special asset management plan established by the Issuer's senior management and core employees for this strategic placement: Guosen Asset Management Betely Employee Participation in ChiNext Strategic Placement No. 1 Collective Asset Management Plan (hereinafter referred to as "Employee Asset Management Plan").
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Large enterprises or their subsidiaries that have strategic cooperative relationships or long-term cooperation intentions with the Issuer's business: Tianjin BOE Innovation Investment Co., Ltd. (hereinafter referred to as "BOE Innovation Investment"), JinkoSolar Co., Ltd. (hereinafter referred to as "JinkoSolar"), Dongguan Industrial Investment Holding Group Co., Ltd. (hereinafter referred to as "Dongshi Group"), and Wuxi DK Electronic Materials Co., Ltd. (hereinafter referred to as "DK Electronic Materials").