Baicheng Pharmaceutical: Legal Opinion from the Shanghai Branch of Beijing Commerce Law Firm on the 2026 Restricted Stock Incentive Plan (Draft) of Hangzhou Baicheng Pharmaceutical Technology Co., Ltd.

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Beijing Commerce Law Firm Shanghai Branch

About Hangzhou Baicheng Pharmaceutical Technology Co., Ltd.

2026 Restricted Stock Incentive Plan (Draft)

legal opinion

To: Hangzhou Baicheng Pharmaceutical Technology Co., Ltd.

In accordance with the Company Law of the People's Republic of China (the "Company Law"), the Securities Law of the People's Republic of China (the "Securities Law"), the Measures for the Administration of Equity Incentives of Listed Companies (the "Administrative Measures"), the Shenzhen Stock Exchange GEM Stock Listing Rules (the "Listing Rules") and the Shenzhen Stock Exchange GEM Listed Companies' Self-Regulatory Guidelines No. 1 No. - Business Processing" ("Self-Regulation Guidelines") and other laws, administrative regulations, departmental rules and normative documents ("Laws and Regulations") and the relevant provisions of the "Articles of Association of Hangzhou Baicheng Pharmaceutical Technology Co., Ltd." ("Articles of Association"), Beijing The Shanghai Branch of Beijing Commerce Law Firm (the "Firm") is entrusted by Hangzhou Baicheng Pharmaceutical Technology Co., Ltd. (the "Company" or "Baicheng Pharmaceutical") to provide legal advice on the matters that the company intends to implement in accordance with the recognized business standards, ethics and spirit of diligence and responsibility in the lawyer industry. This legal opinion is issued regarding the relevant matters involved in the 2026 Restricted Stock Incentive Plan (the “Incentive Plan”).

In order to issue this legal opinion, our firm has verified the relevant facts and legal matters involving the company’s incentive plan in accordance with the current laws and regulations of the People’s Republic of China (“China”, for the purpose of this legal opinion, excluding the Hong Kong Special Administrative Region, the Macau Special Administrative Region and Taiwan) and the Articles of Association.

In accordance with the recognized business standards and ethics of the Chinese lawyer industry, our firm reviewed the documents that we considered necessary to review, including the "Hangzhou Baicheng Pharmaceutical Technology Co., Ltd. 2026 Restricted Stock Incentive Plan (Draft)" and its summary ("Incentive Plan (Draft)") provided by the company, "Hangzhou Baicheng Pharmaceutical Technology Co., Ltd. 2026 Restricted Stock Incentive Plan Implementation Assessment Management Measures" ("Assessment Management Measures"), "Hangzhou Baicheng Pharmaceutical Technology Co., Ltd. List of Incentive Objects First Granted to the Restricted Stock Incentive Plan in 2026 ("Incentive Object List"), documents, records, materials and certificates related to this incentive plan, current relevant laws and regulations, and necessary inquiries and discussions with the company and its senior managers on relevant matters involved in this incentive plan. Our firm issues legal opinions based on the facts that have occurred or existed before the date of issuance of this legal opinion and the relevant provisions of China's current laws and regulations and the Articles of Association.

Our firm only expresses opinions on legal issues related to the company's incentive plan, and does not express opinions on the rationality of the underlying stock value, assessment standards, etc., as well as accounting, financial and other non-legal professional matters involved in the company's incentive plan. When quoting relevant financial data or conclusions in this legal opinion, the Firm has performed the necessary duty of care, but such quotations shall not be deemed as any express or implied guarantee by the Firm as to the authenticity and accuracy of such data and conclusions. For facts that are crucial to the issuance of this legal opinion but cannot be supported by independent evidence, our firm relies on explanations or supporting documents issued by relevant government departments, companies or other relevant units and individuals to issue legal opinions.

The issuance of this legal opinion has been guaranteed by the company as follows:

1. All documents and information provided by the company to the firm and all statements and explanations made by the company are complete, true and valid, and all facts and documents that may affect this legal opinion have been disclosed to the firm without any concealment or major omissions.

2. All signatures and seals in the documents provided by the company are authentic, and the copies, copies or scans of the documents are consistent with the originals.

Our firm has strictly performed its statutory duties, followed the principles of diligence and good faith, and has fully verified the facts and legal issues involved in the company's incentive plan to ensure that the facts identified in this legal opinion are true, accurate, and complete, and that the concluding opinions issued are legal and accurate, and there are no false records, misleading statements, or major omissions, and we shall bear corresponding legal responsibilities.

The Exchange agrees to regard this legal opinion as one of the necessary documents for the company to implement this incentive plan, and to report or announce it together with other materials as a public disclosure document, and assume corresponding legal liability for the legal opinions issued in accordance with the law.

This legal opinion is for the Company’s sole use for the purposes of this Incentive Plan and may not be used for any other purpose. The Exchange agrees that the Company shall quote the relevant contents of this legal opinion in the relevant documents produced for the implementation of this incentive plan. However, when the Company makes the above reference, it shall not cause legal ambiguity or misinterpretation due to the reference. The Exchange reserves the right to review and confirm the corresponding contents of the above-mentioned relevant documents again.

In accordance with the requirements of the Company Law, Securities Law and other relevant laws and regulations, as well as the relevant provisions of the China Securities Regulatory Commission ("CSRC") and the Shenzhen Stock Exchange, and in accordance with the business standards, ethics and diligence and diligence recognized by the lawyer industry, our firm issues the following legal opinions:

1. The company’s qualifications and conditions for implementing this incentive plan

(1) According to the information provided by the company and verified by our lawyers, the company is a joint-stock company established by Hangzhou Baicheng Pharmaceutical Technology Co., Ltd. as a whole. As approved by the China Securities Regulatory Commission's Securities Regulatory Commission [2021] No. 3566 "Reply on Approval of the Registration for the Initial Public Offering of Hangzhou Baicheng Pharmaceutical Technology Co., Ltd.", Baicheng Pharmaceutical's public offering does not exceed 27,041,667 shares. On December 20, 2021, 27,041,667 public shares issued by Baicheng Pharmaceutical were publicly traded on the GEM of the Shenzhen Stock Exchange (hereinafter referred to as the "Shenzhen Stock Exchange"), with the stock code "301096".

(2) The company currently holds a "Business License" with a unified social credit code of 91330108577318224J issued by the Zhejiang Provincial Administration for Market Regulation.

(3) According to the company's currently valid "Business License" and "Articles of Association" and through our lawyers' login to the National Enterprise Credit Information Disclosure System (http://www.gsxt.gov.cn/) for inquiry, as of the date of issuance of this legal opinion, the company is established in accordance with the law and is validly existing, and there is no situation that requires termination according to laws, regulations and the "Articles of Association".

(4) According to the "Audit Report" (Tianjian Shen [2026] No. 8786) and the "Internal Control Audit Report" (Tianjian Shen [2026] No. 8787) issued by Tianjian Accounting Firm (Special General Partnership), the "2025 Annual Report of Hangzhou Baicheng Pharmaceutical Technology Co., Ltd." announced by the company on April 24, 2026, and the company's confirmation and approved by the China Securities Regulatory Commission. “Securities and futures market breach of trust record query platform” (http://neris.csrc.gov.cn/shixinchaxun/honestyObj/query.do) and “Credit China" (https://www.creditchina.gov.cn/). As of the date of issuance of this legal opinion, the company does not have the following circumstances that prohibit the implementation of equity incentives as stipulated in Article 7 of the "Administration Measures":

1. The financial accounting report for the most recent fiscal year was issued a negative opinion or an audit report in which a certified public accountant was unable to express an opinion;

2. The CPA issued an audit report with a negative opinion or a disclaimer of opinion on the internal control of the financial report in the most recent fiscal year;

3. In the last 36 months after listing, there has been any failure to distribute profits in accordance with laws, regulations, Articles of Association, and public commitments;

4. Equity incentives are not allowed according to laws and regulations;

5. Other circumstances determined by the China Securities Regulatory Commission.

In summary, we believe that as of the date of issuance of this legal opinion, the company is a joint-stock company established in accordance with the law and validly existing. There is no situation that prohibits the implementation of equity incentives as stipulated in Article 7 of the "Administration Measures". The company has the qualifications to implement this incentive plan.

2. Legal compliance of the content of this incentive plan

On June 1, 2026, the company held the 11th meeting of the fourth board of directors and reviewed and approved the "Incentive Plan (Draft)", the main contents of which are as follows:

(1) Incentive objects of this incentive plan

According to the "Incentive Plan (Draft)", the incentive objects of this incentive plan are determined in accordance with the "Company Law", "Securities Law", "Administrative Measures", "Listing Rules", "Self-Regulatory Supervision Guide" and other relevant laws, regulations, normative documents and the "Articles of Association", and based on the actual situation of the company. The total number of incentive targets granted by this incentive plan for the first time is 225 in total, including company directors, senior managers, and core technical (business) personnel who were working in the company (including subsidiaries, the same below) when the company announced this incentive plan. Incentive objects do not include independent directors, nor shareholders or actual controllers who individually or collectively hold more than 5% of the company's shares and their spouses, parents, and children.

This incentive plan is intended to be awarded to an employee from Macau, China for the first time. As the general manager of Baicheng Pharmaceutical (Macau) Co., Ltd., he is responsible for the company's business expansion in Macau and plays an important role in operation and management. Therefore, including this employee as an incentive object in this incentive plan is in line with the company's actual situation and development needs, and is necessary and reasonable.

Incentive objects do not have the following circumstances that prohibit them from becoming incentive objects:

1. Those who have been deemed unsuitable candidates by the stock exchange within the last 12 months;

2. Those who have been deemed unsuitable candidates by the China Securities Regulatory Commission and its dispatched offices within the last 12 months;

3. In the past 12 months, the company has been subject to administrative penalties or market ban measures by the China Securities Regulatory Commission and its dispatched agencies due to serious violations of laws and regulations;

4. Those who are prohibited from serving as company directors or senior managers as stipulated in the Company Law;

5. Not allowed to participate in equity incentives of listed companies according to laws and regulations;

6. Other circumstances determined by the China Securities Regulatory Commission.

Among the above incentive objects, all incentive objects must have a labor relationship or employment relationship with the company (including subsidiaries) when the company grants the second type of restricted stock.

The incentive objects for the reserved grant portion will be determined within 12 months after the incentive plan is reviewed and approved by the shareholders' meeting. After the incentive objects are proposed by the board of directors, the remuneration and assessment committee of the board of directors issues clear opinions, and the lawyer expresses professional opinions and issues a legal opinion, the company will promptly disclose relevant information about the current incentive objects on the designated website as required. If the incentive target is not specified for more than 12 months, the reserved rights will become invalid.

According to the "Incentive Plan (Draft)", after the incentive plan is reviewed and approved by the board of directors, the company will publicly announce the names and job categories of the incentive targets internally for a period of not less than 10 days. The Remuneration and Appraisal Committee of the Board of Directors will review the list of incentive objects, fully listen to the public opinions, and disclose the explanation of the review and disclosure of the list of incentive objects by the Remuneration and Appraisal Committee of the Board of Directors 5 days before the company's shareholders meeting to review the incentive plan. The list of incentive targets adjusted by the company's board of directors should also be verified by the remuneration and assessment committee of the board of directors.

In summary, the Exchange believes that this incentive plan clarifies the basis and scope of the incentive objects and complies with the provisions of Article 8 and Article 9 (2) of the Administrative Measures and Article 8.4.2 of the Listing Rules.

(2) Type, source, quantity and allocation of the underlying stocks of this incentive plan

1. According to the "Incentive Plan (Draft)", the source of stocks for this incentive plan is the company's A-share ordinary shares issued by the company to the incentive targets.

2. According to the "Incentive Plan (Draft)", the number of Class II restricted stocks that the company intends to grant to incentive targets shall not exceed 5 million shares, accounting for approximately 4.58% of the company's total share capital of 109.2283 million shares at the time of the announcement of the draft incentive plan. Among them, no more than 4 million shares will be granted for the first time, accounting for approximately 3.66% of the company's total equity of 109.2283 million shares when the draft incentive plan is announced, accounting for 80.00% of the total equity to be granted; no more than 1 million shares will be reserved, accounting for approximately 0.92% of the company's total equity of 109.2283 million shares when the draft incentive plan is announced, accounting for 20.00% of the total equity to be granted.

3. The total number of underlying stocks involved in the company's equity incentive plans within the validity period shall not exceed 20% of the company's total share capital at the time of the announcement of the draft incentive plan. The cumulative number of company shares granted to any incentive target in this incentive plan through all equity incentive plans within the validity period shall not exceed 1% of the company's total share capital at the time of the announcement of the draft incentive plan. According to the "Incentive Plan (Draft)", the distribution of the second type of restricted stocks to be granted under this incentive plan among the incentive objects is as follows:

The proportion of the second type of restricted shares granted to the total share capital of this incentive plan (10,000 shares) on the announcement date.

Deputy general manager, non-independent director

Jia Fei 29.70 5.94% 0.27%

Chen An, deputy general manager 40.50 8.10% 0.37% Miao Lei, deputy general manager 17.00 3.40% 0.16%

Non-Independent Director, Board of Directors

Chen Shufeng 3.00 0.60% 0.03% Secretary, financial person in charge

Yan Hongbing Employee Representative Director 18.13 3.63% 0.17% Company and subsidiaries

Core technical (business) personnel 291.67 58.33% 2.67% (220 people)

Reserved share 100.00 20.00% 0.92%

Total 500.00 100% 4.58%

Note: If there is any difference in the mantissa between some of the totals and the sum of each detailed number in this incentive plan, it is due to the rounding of the above percentage results.

In summary, the Exchange believes that the type, source, quantity and distribution of the subject stocks of this incentive plan comply with the provisions of Article 9 (3), Article 9 (4), Article 12, Article 14 (2), Article 15 of the "Administrative Measures" and Article 8.4.5 of the "Listing Rules".

(3) The validity period, grant date, vesting arrangement and lock-up period of this incentive plan

1. Validity period

According to the "Incentive Plan (Draft)", the validity period of this incentive plan starts from the date of grant of the second type of restricted stocks to the date when all the second type of restricted stocks granted to the incentive objects vest or become invalid, and the longest period shall not exceed 48 months.

2. Grant date

According to the "Incentive Plan (Draft)", the company must grant the second type of restricted stock to the incentive targets for the first time within 60 days after it is reviewed and approved by the shareholders' meeting and complete relevant procedures such as announcement. If the company fails to complete the above work within 60 days, it shall promptly disclose the reasons for failure and terminate the implementation of the second type of restricted stock incentive plan, and the ungranted second type of restricted stock shall become invalid. The company shall specify the incentive objects reserved for grant within 12 months after the incentive plan is reviewed and approved by the shareholders' meeting; if the incentive objects are not specified within 12 months, the second type of restricted stock corresponding to the reserved part shall become invalid.

The grant date will be determined by the company's board of directors after the incentive plan is reviewed and approved by the company's shareholders' meeting. The grant date must be a trading day. If the date determined based on the above principles is a non-trading day, the grant date will be postponed to the first trading day thereafter.

The company may not grant Class II restricted stock during the following periods:

(1) Within 15 days before the company's annual report or semi-annual report is announced, if the announcement date is postponed due to special reasons, the calculation will start from 15 days before the original scheduled announcement date;

(2) Within 5 days before the announcement of the company’s quarterly report, performance forecast, and performance bulletin;

(3) From the date of the occurrence of a major event that may have a greater impact on the trading price of the company's stocks and its derivatives or the date of entry into the decision-making process to the date of disclosure in accordance with the law;

(4) Other periods specified by the China Securities Regulatory Commission and stock exchanges.

The period during which the above-mentioned companies may not grant Class II restricted stock shall not be included in the 60-day period.

3. vesting arrangements for this incentive plan

The second type of restricted stocks granted under this incentive plan will vest in installments according to the agreed proportion after the incentive objects meet the corresponding vesting conditions. The vesting date must be the trading day and shall not vest within the following periods:

(1) Within 15 days before the announcement of the company's annual report or semi-annual report, if the announcement date of the annual report or semi-annual report is postponed due to special reasons, the calculation will start from 15 days before the original scheduled announcement date to 1 day before the announcement;

(2) 5 days before the announcement of the company’s quarterly report, performance forecast, and performance bulletin;

(3) From the date of the occurrence of a major event that may have a greater impact on the trading price of the company's stocks and its derivatives or the date of entry into the decision-making process to the date of disclosure in accordance with the law;

(4) Other periods specified by the China Securities Regulatory Commission and stock exchanges. During the validity period of this incentive plan, if the relevant provisions on the vesting period change, the vesting arrangements shall comply with the revised provisions of relevant laws, regulations, and normative documents.

The vesting period and vesting schedule of each period for the second category of restricted stocks first granted under this incentive plan are as follows:

Amount of vested interests as a percentage of grant vesting arrangement vesting time

Proportion of total equity granted

From the first trading day 12 months after the date of grant to

30% for first vesting period

Ending on the last trading day within 24 months from the date of grant

From the first trading day 24 months after the date of grant to

Second vesting period 30%

Ending on the last trading day within 36 months from the date of grant

From the first trading day 36 months after the date of grant to

Third vesting period 40%

Ends on the last trading day within 48 months from the date of grant

If the reserved portion of the Class II restricted stock is granted before the disclosure of the company's third quarter report in 2026, the vesting period and vesting schedule of each period of the reserved Class II restricted stock will be consistent with the initial grant of the Class II restricted stock. If the reserved portion is granted after the disclosure of the company's third quarter report in 2026, the vesting period and vesting schedule of each period of the reserved portion of the second type of restricted stock are as shown in the following table:

Amount of vested interests as a proportion of vesting arrangements granted vesting time

The proportion of the total equity reserved for the first grant is 50% from the first trading day 24 months after the date of first grant.

Vesting period to the last transaction within 36 months from the date of initial grant

Expired on the same day

Starting from the first trading day 36 months after the date of initial grant

Reserved to grant second

To the last transaction within 48 months from the date of first grant 50%

vesting period

Expired on the same day

If the conditions for vesting in the current period are not fulfilled, the second type of restricted stock shall not vest or be deferred to the next period.

The second type of restricted stock granted to the incentive objects due to capitalization of capital reserve, share subdivision, and allotment of shares is also subject to vesting conditions, and may not be transferred, used to guarantee or repay debts before vesting; if the restricted stock cannot be vested at that time, the shares obtained due to the aforementioned reasons shall also not vest.

4. Lock-up period

There will be no lock-up period after the vested shares of this restricted stock incentive plan vest. If the incentive targets are directors and senior managers of the company, the sales restrictions shall be implemented in accordance with the provisions of the Company Law, Securities Law and other relevant laws, regulations, normative documents and the Articles of Association.

In summary, the Exchange believes that the validity period, grant date, vesting arrangement and lock-up period of this incentive plan are in compliance with Article 9 (5) of the Administrative Measures, Articles 13, 16, 24, 25, Article 8.4.6 of the Listing Rules and the relevant provisions of the Company Law and the Securities Law.

(4) Award price and determination method

1. Grant price of Class II restricted stocks

According to the "Incentive Plan (Draft)", the grant price of the second type of restricted stock granted by this incentive plan (including reserved grant) is 28.50 yuan per share, that is, after meeting the grant conditions and vesting conditions, the incentive objects can purchase the company's A shares of ordinary shares issued by the company to the incentive objects at a price of 28.50 yuan per share.

2. Method for determining the grant price of Class II restricted stocks

According to the "Incentive Plan (Draft)", the grant price of the second type of restricted stock granted under this incentive plan shall not be lower than the par value of the stock, and in principle shall not be lower than the higher of the following prices:

1. 50% of the company’s average stock trading price on the trading day before the announcement of this incentive plan, which is 28.48 yuan per share;

2. 50% of the company’s average stock trading price in the 120 trading days before the announcement of this incentive plan is 27.67 yuan per share.

In summary, the Exchange believes that the grant price and determination method of the restricted stocks in this incentive plan are in compliance with Article 9 (6) and Article 23 of the Administrative Measures and Article 8.4.4 of the Listing Rules.

(5) Grant conditions and vesting conditions for the second type of restricted stocks

1. Grant conditions for Class II restricted stocks

According to the "Incentive Plan (Draft)", when the following grant conditions are met at the same time, the company shall grant the second type of restricted stock to the incentive target. On the contrary, if any of the following grant conditions is not met, the second type of restricted stock cannot be granted to the incentive target.

(1) The company has not experienced any of the following situations:

1. The financial accounting report of the most recent fiscal year was issued a negative opinion or an audit report in which a certified public accountant was unable to express an opinion;

2. A certified public accountant issued an audit report with a negative opinion or a disclaimer of opinion on the internal control of the financial report in the most recent fiscal year;

3. There has been any failure to distribute profits in accordance with laws, regulations, articles of association, and public commitments within the last 36 months after listing;

4. Equity incentives are not allowed according to laws and regulations;

5. Other circumstances determined by the China Securities Regulatory Commission.

(2) None of the following situations occurs to the incentive objects:

1. Has been deemed unsuitable by the stock exchange within the last 12 months;

2. Have been deemed as inappropriate candidates by the China Securities Regulatory Commission and its dispatched agencies within the last 12 months;

3. In the past 12 months, the company has been subject to administrative penalties or market ban measures by the China Securities Regulatory Commission and its dispatched agencies due to serious violations of laws and regulations;

4. Those who are prohibited from serving as company directors or senior managers as stipulated in the Company Law;

5. Laws and regulations stipulate that you are not allowed to participate in equity incentives of listed companies;

6. Other circumstances determined by the China Securities Regulatory Commission.

2. vesting conditions for the second type of restricted stocks

In addition to meeting the above grant conditions, the restricted stocks that have been granted to the incentive objects must also meet the following conditions before they can vest:

(1) Performance appraisal requirements at the incentive target company level

The assessment years for the incentive objects of the first category II restricted stock granted under this incentive plan are the three fiscal years from 2026 to 2028, and the assessment years for the reserved incentive objects are the two fiscal years from 2027 to 2028. The assessment is once for each fiscal year. The performance assessment targets for each year are as shown in the following table:

Vesting period Assessment year Performance assessment target (meet any indicator)

1. Based on the operating income in 2025, the company’s operating income growth rate in 2026 will not be lower than 4%, or

2026

Period 2) Taking the net profit in 2025 as the base, the company’s net profit growth rate in 2026 will not be less than 100%

1. Based on the operating income in 2025, the company’s operating income growth rate in 2027 will not be lower than 19%, or

2027

Period 2) Based on the net profit in 2025, the company’s net profit growth rate in 2027 will not be less than 122%

1. Based on the operating income in 2025, the company’s operating income growth rate in 2028 will not be less than 34%, or

2028

Period 2) Based on the net profit in 2025, the company’s net profit growth rate in 2028 will not be less than 144%

If the reserved part of the second type of restricted stock is granted before the disclosure of the company's third quarter report in 2026, the annual performance assessment of the reserved type of restricted stock will be consistent with the first grant; if the reserved part of the second type restricted stock is granted after the disclosure of the company's 2026 third quarter report, the annual performance assessment targets of the reserved part of the second type restricted stock are as follows:

Vesting period Assessment year Performance assessment target (meet any indicator)

1. Based on the operating income in 2025, the company’s operating income growth rate in 2027 is less than 19%, or

2027

One vesting period 2) Based on the net profit in 2025, the company’s net profit growth rate in 2027 will not be less than 122%

1. Based on the operating income in 2025, the company’s operating income growth rate in 2028 is less than 34%, or

2028

Two vesting periods 2) Taking the net profit in 2025 as the base, the company’s net profit growth rate in 2028 will not be less than

144%

Note: 1. The above "net profit" refers to the audited net profit attributable to shareholders of listed companies, but the value excluding the impact of share-based payment expenses of this and other employee incentive plans is used as the basis for calculation.

If the company fails to meet the above-mentioned performance assessment goals, all the second-class restricted stocks planned to vest in the current year corresponding to the incentive objects shall not be vested and will be invalidated by the company.

(2) Performance appraisal requirements at the individual level for incentive targets

According to the "Appraisal Management Measures" formulated by the company, the individual-level assessment of incentive targets is implemented in accordance with the company's internal performance appraisal related systems. The company confirms the individual-level vesting coefficient based on the individual assessment results (S) of the incentive objects in the corresponding assessment year. The individual assessment and evaluation results of the incentive objects are divided into three assessment levels. The corresponding attributable situations are as follows:

Personal assessment results S≥90 85≤S<90 S<85 Personal level attribution coefficient 100% 70% 0%

On the premise that the company's performance goals are achieved, the actual number of restricted stocks that can be vested by the individual incentive target in the current year = the number of individuals planned to vest in the current year × the individual-level vesting coefficient.

If the restricted stocks vested in the current plan of the incentive target cannot be vested or cannot be fully vested due to assessment reasons, they will be invalid and cannot be deferred to the next year.

In summary, the Exchange believes that the grant conditions and vesting conditions of the restricted stocks in this incentive plan comply with the provisions of Articles 7, 8, Article 9 (7), Article 10, Article 11, and Article 18 of the Administrative Measures and Article 8.4.6 of the Listing Rules.

(6) Others

The "Incentive Plan (Draft)" stipulates the purpose and principles of this incentive plan, adjustment methods and procedures, accounting treatment methods, implementation procedures, the respective rights and obligations of the company/incentive objects, the handling, change and termination of changes in the company/incentive objects, repurchase and cancellation, etc.

In summary, the Exchange believes that the above contents of the "Incentive Plan (Draft)" are in compliance with the relevant provisions of the "Administrative Measures" and the "Listing Rules".

3. Legal procedures involved in this incentive plan

(1) Legal procedures that have been performed

According to the board resolutions, opinions of independent directors, "Incentive Plan (Draft)" and other relevant documents provided by the company, as of the date of issuance of this legal opinion, in order to implement this incentive plan, the company has performed the following procedures:

1. On June 1, 2026, the Remuneration and Assessment Committee of the company's board of directors reviewed and formulated the "Incentive Plan (Draft)" and "Appraisal Management Measures" and submitted them to the 11th meeting of the company's fourth board of directors for review.

2. The Remuneration and Assessment Committee of the company's board of directors issued the "Verification Opinions on Matters Related to the 2026 Restricted Stock Incentive Plan" and agreed to the company's implementation of this incentive plan.

3. On June 1, 2026, the company held the eleventh meeting of the fourth session of the board of directors, which reviewed and approved the "Proposal on the Company's <2026 Restricted Stock Incentive Plan (Draft)> and its Summary", the "Proposal on the Company's <2026 Restricted Stock Incentive Plan Implementation Assessment Management Measures>" and the "Proposal on Requesting the Shareholders Meeting to Authorize the Board of Directors to Handle Matters Related to the 2026 Restricted Stock Incentive Plan" and other relevant proposals.

(2) Legal procedures that still need to be performed

According to the "Administrative Measures" and other relevant laws and regulations, the company still needs to perform the following procedures to implement this incentive plan:

1. The company will publicize the names and positions of the incentive targets within the company through the company's website or other channels before convening the shareholders' meeting. The publicity period shall be no less than 10 days. The remuneration and assessment committee of the board of directors should review the equity incentive list and fully listen to public opinions. The company shall disclose the Board's Compensation and Assessment Committee's explanation of the review opinions and publicity of the incentive list 5 days before the shareholders' meeting to review the incentive plan.

2. The company should conduct a self-examination on the insider trading of the company’s stocks and their derivatives within 6 months before the announcement of the draft equity incentive plan, and explain whether there is insider trading.

3. The shareholders' meeting shall vote on the contents of this incentive plan and shall be approved by more than 2/3 of the voting rights held by shareholders attending the meeting. Except for the company's directors, senior managers, and shareholders who individually or collectively hold more than 5% of the company's shares, the voting information of other shareholders shall be counted separately and disclosed. When the company's shareholders meeting reviews this incentive plan, shareholders who are intended to be the incentive targets or shareholders who are related to the incentive targets should abstain from voting.

4. When this incentive plan is reviewed and approved by the company's shareholders' meeting and meets the grant conditions stipulated in this incentive plan, the company will grant rights and interests to the incentive objects within the specified time. After authorization from the shareholders' meeting, the board of directors is responsible for the granting, vesting and invalidation of the second type of restricted stocks.

In summary, we believe that as of the date of issuance of this legal opinion, the company has performed the legal procedures that should be performed at this stage with respect to this incentive plan; the company still needs to perform relevant legal procedures in accordance with the "Administrative Measures", "Listing Rules" and other relevant laws and regulations and the "Articles of Association", and it can only be implemented after being reviewed and approved by the company's shareholders' meeting.

4. Legality and Compliance of Determination of Incentive Objects

Please refer to "II. (1) Incentive Objects of this Incentive Plan" of this legal opinion for details such as the basis and scope for determining the incentive objects of this equity incentive plan.

For those who meet the scope of the incentive targets of this equity incentive plan, after the equity incentive plan is reviewed and approved by the company's board of directors, it will be publicized within the company for no less than 10 days. The company's remuneration and assessment committee will review the incentive list and fully listen to public opinions. The company will disclose the board's remuneration and assessment committee's explanation of the review and publicity of the incentive target list 5 days before the shareholders' meeting to review the incentive plan.

To sum up, our lawyers believe that the determination of incentive objects complies with the provisions of the "Administrative Measures", "Listing Rules" and relevant laws and regulations.

5. Information disclosure of this incentive plan

After the company has reviewed and approved the proposals related to this equity incentive plan at the eleventh meeting of the fourth session of the board of directors, in accordance with the provisions of Articles 54 and 56 of the "Administration Measures", the company shall announce the "Equity Incentive Plan (Draft)" and its summary, "Appraisal Management Measures", board resolutions and other documents together with this legal opinion, and perform the corresponding information disclosure obligations. In addition, as the implementation of this incentive plan progresses, the company shall fulfill its continuous information disclosure obligations in accordance with the "Administrative Measures", "Listing Rules" and relevant laws and regulations.

6. There is no situation of providing financial assistance to incentive objects.

According to the "Incentive Plan (Draft)", the company promises not to provide loans, guarantees for their loans, or any other form of financial assistance for the incentive targets to obtain relevant second-category restricted stocks in accordance with this incentive plan, which will harm the interests of the company, in line with the provisions of Article 21 of the "Administration Measures".

7. There is no situation that obviously damages the interests of the company and all shareholders.

According to the "Incentive Plan (Draft)", the purpose of this incentive plan is: "In order to further improve the company's long-term incentive mechanism, attract and retain outstanding talents, fully mobilize the enthusiasm of the company's employees, and effectively combine the interests of shareholders, the company's interests and the core team's personal interests, so that all parties can jointly pay attention to the company's long-term development."

According to the resolution of the third meeting of the Remuneration and Assessment Committee of the fourth session of the Board of Directors, the Remuneration and Assessment Committee of the Company's Board of Directors has issued an opinion on whether this equity incentive plan harms the interests and legality of the company and shareholders, and believes that this equity incentive plan complies with the provisions of laws, regulations and normative documents, and does not harm the interests of the company and all shareholders.

In summary, the Exchange believes that this incentive plan does not significantly harm the interests of the company and all shareholders, and it complies with the provisions of Article 3 of the "Administration Measures".

8. Incentive directors and related directors’ avoidance of voting

The company held the 11th meeting of the fourth session of the Board of Directors on June 1, 2026, and reviewed and approved the "Proposal on the Company's 2026 Restricted Stock Incentive Plan (Draft)" and its Summary, the "Proposal on the Company's "2026 Restricted Stock Incentive Plan Implementation Assessment and Management Measures" and "Requesting the Shareholders' Meeting to Authorize the Board of Directors to Handle the 2026 Restricted Stock Incentive Plan" "Proposal on Matters Related to the 2018 Restricted Stock Incentive Plan" and other related proposals, related directors have abstained from voting, which is in compliance with the provisions of Article 33 of the "Management Measures".

9. Conclusion

In summary, we believe that, as of the date of issuance of this legal opinion, the company has the subject qualifications to implement this incentive plan as stipulated in the "Administrative Measures"; the content of the "Incentive Plan (Draft)" formulated by the company to implement this incentive plan complies with the relevant provisions of the "Administrative Measures" and the "Listing Rules"; the company has performed the legal procedures that should be performed at this stage with respect to this incentive plan; the determination of the incentive objects of this incentive plan complies with the "Administrative Measures" The relevant provisions of the "Listing Rules"; the company does not provide loans to incentive targets, provide guarantees for their loans, or provide any other form of financial assistance; this incentive plan does not significantly harm the interests of the company and all shareholders; the associated directors have abstained from voting; this incentive plan is subject to review and approval by the company's shareholders' meeting before it can be implemented. The company still needs to perform corresponding follow-up procedures and information disclosure obligations in accordance with relevant laws, administrative regulations, normative documents and relevant provisions of the China Securities Regulatory Commission.

This legal opinion is made in triplicate.

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