Legal Opinion from Beijing Hairun Tianrui Law Firm on the Distribution of Differentiated Rights and Interests of Zhejiang Aoxiang Pharmaceutical Co., Ltd.

Beijing Hairun Tianrui Law Firm

Legal Opinion on the Distribution of Differentiated Rights and Interests of Zhejiang Aoxiang Pharmaceutical Co., Ltd.

China·Beijing

Address: Floor 5/9/10/13/17, Broadcasting Building, No. 14, Jianwai Street, Chaoyang District, Beijing Tel: (010) 65219696 Fax: (010) 88381869

June 2026

Beijing Hairun Tianrui Law Firm

About the differentiated equity distribution of Zhejiang Aoxiang Pharmaceutical Co., Ltd.

Legal opinions on matters

To: Zhejiang Aoxiang Pharmaceutical Co., Ltd.

In accordance with the Company Law of the People's Republic of China (hereinafter referred to as the "Company Law"), the Securities Law of the People's Republic of China (hereinafter referred to as the "Securities Law"), the Rules for Share Repurchase of Listed Companies (hereinafter referred to as the "Repurchase Rules"), and the "Shanghai Stock Exchange Self-Discipline Supervision Guidelines for Listed Companies No. 7 - Repurchase of Shares" (hereinafter referred to as "Regulatory Guidelines No. 7") ""), the "Stock Listing Rules of the Shanghai Stock Exchange" (hereinafter referred to as the "Listing Rules") and other relevant laws, regulations and normative documents, as well as the "Articles of Association of Zhejiang Aoxiang Pharmaceutical Co., Ltd.", our lawyers issued this legal opinion on matters related to the special ex-rights and ex-dividends for differentiated equity distribution (hereinafter referred to as "this differentiated equity distribution") involved in the 2025 profit distribution of Zhejiang Aoxiang Pharmaceutical Co., Ltd. (hereinafter referred to as the "Company").

In accordance with the recognized business standards, ethics and diligence of the legal industry, and based on the facts that have occurred or existed before the date of issuance of this legal opinion, our lawyers issued a legal opinion and stated as follows:

1. The firm and its handling lawyers have strictly fulfilled statutory obligations in accordance with the provisions of the Securities Law of the People's Republic of China, the Administrative Measures for Law Firms Engaging in Securities Legal Business, the Rules for the Practice of Securities Legal Business of Law Firms, and the facts that have occurred or existed before the date of issuance of this legal opinion. Responsibilities, following the principles of diligence and good faith, conducting sufficient verification and verification to ensure that the facts identified in this legal opinion are true, accurate, and complete, the concluding opinions issued are legal and accurate, and there are no false records, misleading statements, or major omissions, and corresponding legal responsibilities shall be assumed.

2. The company and relevant parties have guaranteed that: they have provided the lawyers of our firm with authentic, complete and valid original written materials, copies of materials or oral testimonies necessary for the issuance of this legal opinion, and that the relevant written materials and testimonies are true and valid without any major omissions or misleading statements, and the copies provided are consistent with the originals.

3. For facts that are crucial to this legal opinion but cannot be supported by independent evidence, our lawyers rely on supporting documents issued by relevant government departments, companies or other relevant units.

4. Our lawyers only express opinions on the legality of the company’s differentiated equity distribution and related Chinese legal issues. When issuing this legal opinion, our lawyers have fulfilled the special obligations of legal professionals on legal-related business matters and the general obligations of ordinary people on other business matters. The documents produced and issued do not contain false records, misleading statements or major omissions.

5. Our lawyers agree that the company shall quote and disclose the contents of this legal opinion in accordance with the review requirements of the China Securities Regulatory Commission and the Shanghai Stock Exchange. However, when the company makes the above quotations and disclosures, it shall not cause legal ambiguity or misinterpretation due to the quotation and disclosure, and the relevant contents quoted and disclosed must be reviewed and confirmed by our lawyers. This legal opinion is only for the purpose of this differentiated equity distribution matter. No unit or individual may use this legal opinion or any part of it for any other purpose unless prior written authorization has been obtained from our lawyers.

Our lawyers now issue the following legal opinions:

1. Reasons for this differentiated equity distribution

On January 24, 2025, the company held the sixth meeting of the fourth session of the board of directors, and reviewed and approved the "Proposal on the Plan to Repurchase the Company's Shares through Centralized Bidding Transactions", agreeing that the company will use its own funds and/or self-raised funds to repurchase some of the company's issued RMB ordinary shares (A shares) through centralized bidding transactions. The shares repurchased this time are planned to be used to implement equity incentives and/or employee stock ownership plans in the future. The total amount of funds for this repurchase shall not be less than RMB 50 million (inclusive) and shall not exceed RMB 100 million (inclusive). The repurchase price shall not exceed RMB 14/share (inclusive). The repurchase period shall be within 12 months from the date on which the company's board of directors considers and approves the share repurchase plan.

According to the "Announcement of Aoxiang Pharmaceutical on the Implementation Results of Share Repurchases and Changes in Shares" disclosed by the company on January 24, 2026, as of January 2026 On the 23rd, the company repurchased a total of 5,201,200 shares of the company through centralized bidding transactions through the Shanghai Stock Exchange trading system, accounting for 0.63% of the company's total share capital. The highest transaction price was 11.39 yuan/share and the lowest price was 7.52 yuan/share. The total amount paid was RMB 50,006,023.36 (excluding transaction fees). The share repurchase plan has been completed.

As of the date of issuance of this legal opinion, the company's special repurchase securities account holds 5,201,200 shares, accounting for 0.63% of the company's total 830,297,145 shares.

According to the "Repurchase Rules", "Regulatory Guidelines No. 7" and other relevant laws, administrative regulations, departmental rules and other normative documents, as well as the relevant provisions of the "Articles of Association", the shares repurchased by the above-mentioned companies will not participate in profit distribution. Therefore, the company's annual equity distribution in 2025 will implement differentiated equity distribution.

2. Specific plan for this differentiated equity distribution

According to the "Proposal on the Profit Distribution Plan for 2025" reviewed and approved at the 11th meeting of the company's fourth board of directors on April 27, 2026 and the company's 2025 annual shareholders' meeting on May 20, 2026, the profit distribution plan is as follows:

The company plans to distribute a cash dividend of RMB 0.64 (tax included) to all shareholders for every 10 shares. As of June 18, 2026, the company's total share capital is 830,297,145 shares. After deducting the number of 5,201,200 shares in the company's special securities account for repurchase, the actual number of shares distributed this time is 825,095,945 shares. Based on this calculation, the total cash dividend to be distributed is 52,806,140.48 yuan (tax included). This year, no capital reserve will be converted into share capital, and no bonus shares will be issued.

3. Calculation basis for this differentiated equity distribution

According to the provisions of relevant laws, administrative regulations, departmental rules and other normative documents, the ex-rights (dividend) reference price is calculated according to the following formula:

Impact of ex-rights (dividend) reference price = |Ex-rights (dividend) reference price calculated based on actual distribution - Ex-rights (dividend) reference price calculated based on fictitious distribution|÷Ex-right (dividend) reference price calculated based on actual distribution

Ex-rights (dividend) reference price = (previous closing price - cash dividend) ÷ (1 + change ratio of circulating shares)

Virtually distributed cash dividend = (total number of shares participating in distribution × actual cash dividend per share distributed) ÷ total share capital

Change ratio of circulating shares of virtual distribution = (total number of shares participating in distribution × transfer ratio of actual distribution) ÷ total share capital

The specific calculation is as follows:

Since all the company's shares are tradable shares, the company's current total share capital is 830,297,145 shares. The number of shares participating in this distribution is 825,095,945 shares. The 5,201,200 shares that have been repurchased will not participate in this distribution. According to the profit distribution plan reviewed and approved by the company's 2025 annual shareholders' meeting, and the closing price of the previous trading day (June 17, 2026) was 8.30 yuan/share.

The company will only distribute cash dividends this time, and will not convert capital reserves into share capital and will not issue bonus shares. Therefore, the company's outstanding shares will not change, and the change ratio of outstanding shares is 0.

1. Actual cash dividend distributed per share = 0.064 yuan

Ex-rights (dividend) reference price = (previous closing price - cash dividend) ÷ (1 + change ratio of circulating shares) = (8.30-0.064) ÷ (1 + 0) ≈ 8.24 yuan/share.

2. Such as differentiated dividends

Virtually distributed cash dividend = (825,095,945×0.064)÷830,297,145≈0.064 yuan/share;

Ex-rights (dividend) reference price = (previous closing price - virtual distributed cash dividend) ÷ (1 + change ratio of circulating shares) = (8.30-0.064) ÷ (1 + 0) ≈ 8.24 yuan/share.

Impact of ex-rights (dividend) reference price

Impact of ex-rights (dividend) reference price = |Ex-rights (dividend) reference price calculated based on actual distribution - Ex-rights (dividend) reference price calculated based on virtual distribution|÷Ex-rights (dividend) reference price calculated based on actual distribution =|(8.24-8.24)|÷8.24≈0.00%<1%. The absolute value of the impact of differentiated equity distribution on the ex-rights (dividend) reference price of A shares is less than 1%.

Therefore, the absolute value of the impact of differentiated equity distribution on the ex-rights (dividend) reference price is less than 1%, and the impact is small.

4. Conclusions

After verification, our lawyers believe that the company's differentiated equity distribution complies with the provisions of the Company Law, Securities Law, Buyback Rules, Supervisory Guidelines No. 7 and other relevant laws, regulations, normative documents, and the Articles of Association, and does not harm the interests of the company and all shareholders.

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