/Boyuan New Materials: Legal opinion from Shanghai AllBright (Qingdao) Law Firm on the first extraordinary shareholders’ meeting of Shandong Boyuan New Materials Co., Ltd. in 2026

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Boyuan New Materials: Legal opinion from Shanghai AllBright (Qingdao) Law Firm on the first extraordinary shareholders’ meeting of Shandong Boyuan New Materials Co., Ltd. in 2026

Shenzhen Stock Exchange

2026/09/04

Shanghai AllBright (Qingdao) Law Firm’s Notice on the First Extraordinary Shareholders Meeting of Shandong Boyuan New Materials Co., Ltd. in 2026

legal opinion

Address: 45th Floor, Tower A, Qingdao Central Building, No. 8 Hong Kong Middle Road, Shinan District, Qingdao City, Shandong Province Tel: 0532-55769166 Fax: 0532-55769155 Postal Code: 266071 Shandong Boyuan New Materials Co., Ltd. AllBright·Legal Opinion

Shanghai AllBright (Qingdao) Law Firm

About Shandong Boyuan New Materials Co., Ltd.

The first extraordinary shareholders’ meeting in 2026

legal opinion

To Shandong Boyuan New Materials Co., Ltd.:

Shanghai AllBright (Qingdao) Law Firm (hereinafter referred to as the "firm") accepted the entrustment of Shandong Boyuan New Materials Co., Ltd. (hereinafter referred to as the "company") and assigned lawyers Wang Rui and Zhang Xiaomin to attend the company's first extraordinary shareholders' meeting of 2026 held on September 4, 2026 (hereinafter referred to as the "shareholders' meeting"). Now 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 of Shareholders' Meetings of Listed Companies", "Shenzhen Stock Exchange Listed Companies Self-Regulatory Guidelines No. 2 - Standardized Operation of GEM Listed Companies" and other laws, administrative regulations, normative documents and "Shandong Bo "Articles of Association of Yuan New Materials Co., Ltd." (hereinafter referred to as "Articles of Association"), this legal opinion is issued on whether the convening and convening procedures of this shareholders' meeting comply with the provisions of laws, administrative regulations, normative documents and the "Articles of Association", whether the qualifications of the persons attending the meeting and the qualifications of the convener are legal and valid, and whether the voting procedures and voting results are legal and valid.

In order to issue this legal opinion, our lawyers reviewed the matters involved in this shareholders' meeting, reviewed the documents and information that our lawyers believed were necessary to issue this legal opinion, and conducted necessary verification and verification of relevant issues.

The Exchange agrees to announce this legal opinion together with the resolutions of this shareholders' meeting, and assumes corresponding legal responsibilities for the legal opinions issued in accordance with the law.

Based on their knowledge of the relevant facts and understanding of the law, and in accordance with the recognized business standards, ethics and diligence of the legal industry, our lawyers issue the following legal opinions:

1. Convening and convening procedures of this shareholders’ meeting

(1) Convening of this shareholders’ meeting

On August 18, 2026, the company held the 14th meeting of the second board of directors and decided to convene this shareholders' meeting.

Shandong Boyuan New Materials Co., Ltd. AllBright·Legal Opinion

On August 20, 2026, the company's board of directors issued the "Notice on Convening the First Extraordinary Shareholders' Meeting in 2026" through cninfo.com. The aforementioned meeting notice stated the convener of this shareholders' meeting, the date and time of the shareholders' meeting (including the date and time of the on-site meeting and the date and time of online voting), the convening method, the equity registration date, the attendees, the meeting location, the matters to be considered at the meeting, the on-site meeting registration method, the specific operating procedures for participating in online voting, the meeting contact person and contact information, and "as of All shareholders of the company registered at the Shenzhen Branch of China Securities Depository and Clearing Co., Ltd. at the market close on the afternoon of August 31, 2026 (Monday) are entitled to attend this meeting and participate in voting. Shareholders who are unable to attend the meeting in person for some reason may entrust a proxy in writing to attend and vote on their behalf. The shareholder proxy does not need to be a shareholder of the company."

(2) Convening of this shareholders’ meeting

In accordance with the aforementioned announcement, the on-site meeting of the shareholders' meeting was held as scheduled at 14:30 pm on September 4, 2026, in the conference room of Shandong Boyuan New Materials Co., Ltd., 200 meters north of the intersection of Xinhai Road and Dajiu Road, Houzhen Ocean Chemical Park, Shouguang City, Shandong Province, and was chaired by Mr. Li Chenglin, chairman of the company.

This shareholders' meeting will be held through a combination of on-site voting and online voting. The specific time for online voting of this shareholders' meeting through the Shenzhen Stock Exchange trading system is 09:15-09:25, 09:30-11:30, 13:00-15:00 on September 4, 2026; the time for voting through the Shenzhen Stock Exchange's Internet voting system is any time between 9:15-15:00 on September 4, 2026.

After verification by our lawyers, the company's board of directors convened this shareholders' meeting in accordance with the relevant provisions of the Company Law, other laws, regulations, normative documents and the Articles of Association, and disclosed the time and date of the shareholders' meeting in the information disclosure media designated by the Articles of Association within the prescribed time limit. The location, convener of the meeting, attendees, proposals for review, meeting registration methods and other matters were fully disclosed. The actual time, location and other matters of this shareholders’ meeting were consistent with those disclosed in the “Notice on Convening the First Extraordinary Shareholders’ Meeting in 2026”.

In summary, our lawyers believe that the convening and procedures of this shareholders’ meeting comply with the provisions of the Company Law, the Rules of Shareholders’ Meetings of Listed Companies and the Articles of Association.

2. Qualifications of the convener of this shareholders’ meeting and those attending the meeting

(1) This shareholders’ meeting is convened by the company’s board of directors.

(2) Personnel attending this shareholders’ meeting

Shandong Boyuan New Materials Co., Ltd. AllBright·Legal Opinion

After verification of the identity certificates, power of attorney and shareholder registration materials of the shareholders and shareholders' agents who attended the shareholders' meeting, a total of 5 shareholders and shareholder representatives attended the on-site meeting of shareholders, all of whom were ordinary shareholders registered in the Shenzhen Branch of China Securities Depository and Clearing Co., Ltd. shares, accounting for 61.0195% of the company’s total voting shares.

According to the statistical results provided by Shenzhen Securities Information Co., Ltd., a total of 63 shareholders participated in this shareholders' meeting through online voting, representing 124,964 shares, accounting for 0.0719% of the company's total voting shares. The qualifications of the above-mentioned shareholders participating in online voting have been certified by the Shenzhen Stock Exchange trading system and Internet voting system.

Accordingly, a total of 68 shareholders and shareholder authorized representatives attended the on-site meeting and voted online, representing 106,135,422 shares, accounting for 61.0915% of the company’s total voting shares. Among them, a total of 63 small and medium-sized investors participated in this meeting on-site and online, owning and representing 124,964 shares, accounting for 0.0719% of the company's total voting shares.

(3) Some of the company’s directors, senior managers and lawyers of the firm were also present at the on-site shareholders’ meeting.

After verification by our lawyers, the qualifications of the convener and attendees of this shareholders’ meeting comply with the relevant provisions of the Company Law, the Rules of Shareholders’ Meetings of Listed Companies and the Articles of Association, and are legal and valid.

3. Proposals of this Shareholders’ Meeting

This shareholders’ meeting considered the following proposals:

"Proposal on Amending Some Corporate Governance Systems"

1.01 "Proposal on Amending the Rules of Procedure for Shareholders' Meetings"

1.02 "Proposal on Amending the Rules of Procedure of the Board of Directors"

1.03 "Proposal on Amending the "Working System of Independent Directors""

1.04 "Proposal on Amending the "Raised Funds Management System""

1.05 "Proposal on Amending the "Related Transaction Management System""

"Proposal on Amending the Articles of Association"
"Proposal on Adjusting the Construction Content of Partially Raised Funds Investment Projects"

Shandong Boyuan New Materials Co., Ltd. AllBright·Legal Opinion 4. "Proposal on the General Election of the Company's Board of Directors and Nomination of Non-Independent Director Candidates for the Third Board of Directors" 4.01 Elect Mr. Li Chenglin as a non-independent director of the Company's third Board of Directors

4.02 Mr. Yu Guoqing was elected as a non-independent director of the third session of the company’s board of directors

4.03 Mr. Wang Enxun was elected as a non-independent director of the third session of the company’s board of directors

"Proposal on the General Election of the Company's Board of Directors and Nomination of Candidates for Independent Directors of the Third Board of Directors" 5.01 Elect Ms. Wang Dongmei as an independent director of the third session of the Company's Board of Directors

5.02 Mr. Wang Weiguo was elected as an independent director of the company’s third board of directors

5.03 Mr. Pan Helin was elected as an independent director of the third session of the company’s board of directors

After verification by our lawyers, the proposals reviewed at this shareholders’ meeting are consistent with the proposals listed in the notice of shareholders’ meeting. There is no situation in this shareholders’ meeting to modify the proposals listed in the notice of shareholders’ meeting.

4. Voting procedures and results of this shareholders’ meeting

This shareholders' meeting used a combination of on-site voting and online voting to review and vote on the proposals included on the agenda, and neither shelved nor voted on them for any reason. Among them, the shareholders who attended the on-site meeting voted on the proposals item by item by written vote; the votes were counted and supervised by the shareholder representatives and the lawyers of the firm. After the online voting of this meeting ended, Shenzhen Securities Information Co., Ltd. provided the company with the voting rights and voting results statistics of the online voting of this shareholders’ meeting.

After combining the voting results of on-site voting and online voting, the voting results are as follows:

"Proposal on Amending Some Corporate Governance Systems"

1.01 "Proposal on Amending the Rules of Procedure for Shareholders' Meetings"

Voting results: 106,113,137 shares were approved, accounting for 99.9790% of the total number of shares with valid voting rights present at this shareholders' meeting; 21,285 shares were opposed, accounting for 0.0201% of the total number of shares with valid voting rights present at this shareholders' meeting; 1,000 shares were abstained (of which 0 shares were abstained by default due to non-voting), accounting for 0.0009% of the total number of shares with valid voting rights present at this shareholders' meeting.

Among them, the voting results of small and medium-sized investors were: 102,679 shares were approved, accounting for 82.1669% of the total number of shares with valid voting rights of small and medium-sized shareholders attending this shareholders' meeting; 21,285 shares were opposed, accounting for 17.0329% of the total number of shares with valid voting rights of small and medium-sized shareholders attending this shareholders' meeting; 1,000 shares were abstained (of which, due to failure to vote, they abstained by default) 0 shares), accounting for 0.8002% of the total number of shares with valid voting rights of small and medium-sized shareholders attending this shareholders’ meeting.