Grandall Law Firm (Shanghai).

About Shanghai Silicon Industry Group Co., Ltd

Legal opinion of the first extraordinary general meeting of shareholders in 2025

To: Shanghai Silicon Industry Group Co., Ltd

Grandall Law Firm (Shanghai) (hereinafter referred to as the "Firm") was entrusted by Shanghai Silicon Industry Group Co., Ltd. (hereinafter referred to as the "Company") to appoint Mr. He Yangyang and Mr. Wang Jianchi (hereinafter referred to as the "Firm's Lawyers") to attend the Company's first extraordinary general meeting of shareholders in 2025 (hereinafter referred to as the "General Meeting of Shareholders"). Our lawyers comply 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") and other laws and regulations, the Rules of the General Meeting of Shareholders of Listed Companies (hereinafter referred to as the "Rules of the General Meeting of Shareholders") of the China Securities Regulatory Commission (hereinafter referred to as the "CSRC") and other laws, regulations, departmental rules and normative documents, as well as the Articles of Association of Shanghai Silicon Industry Group Co., Ltd. (hereinafter referred to as the "Articles of Association") On the convening and convening procedures of the general meeting of shareholders, the qualifications of the persons attending the meeting, the qualifications of the convener, the voting procedures of the general meeting of shareholders and the legality of the voting results, and other relevant legal issues are issued.

In order to issue this legal opinion, the lawyer of the firm reviewed the relevant matters involved in the company's general meeting of shareholders, consulted the documents that the lawyer of the firm believes must be consulted to issue this legal opinion, and carried out the necessary verification and verification of the relevant issues.

This legal opinion is only for the purpose of witnessing this general meeting of shareholders and shall not be used for any other purpose.

The lawyer of the firm agrees to announce this legal opinion together with the resolution of the company's general meeting of shareholders, and assume corresponding responsibilities for this legal opinion in accordance with the law.

In accordance with the requirements of relevant laws, regulations, departmental rules and normative documents, and in accordance with the recognized professional standards, ethics and diligence of the lawyer industry, the lawyers of the firm issue legal opinions as follows:

1. The convening and convening procedures of the general meeting of shareholders

The Board of Directors of the Company was announced on the official website of the Shanghai Stock Exchange on February 13, 2025

(http://www.sse.com.cn/) The Notice of Shanghai Silicon Industry Group Co., Ltd. on Convening the First Extraordinary General Meeting of Shareholders in 2025 (hereinafter referred to as the "Meeting Notice") was published in the form of an announcement. After verification, it will

The notice of meeting specifies the time, content and place of the meeting, and explains the share registration date of the shareholders who are entitled to attend the meeting, the registration method of the shareholders attending the meeting, the contact telephone number and the name of the contact person.

The general meeting of shareholders will be held on Friday, February 28, 2025, with on-site voting and online voting

Tickets are combined in the way of an on-site meeting on Friday, February 28, 2025 at 14:00 p.m. in Shanghai

The conference room on the first floor of No. 200 Xinlai Road in Dingqu was held, and Mr. Yu Yuehui, chairman of the company, presided over the on-site meeting; The company provides shareholders with an online voting platform through the online voting system of the general meeting of shareholders of the Shanghai Stock Exchange

The time for online voting through the voting platform of the trading system is February 28, 2025 (Friday) 9:15-9:25.

9:30-11:30，13:00-15:00。

2. Qualifications of the on-site meeting and convener of the general meeting of shareholders

1. The convener of the general meeting of shareholders

It has been verified that the general meeting of shareholders was convened by the board of directors of the company and issued a notice announcement, and the qualification of the board of directors of the company as the convener is legal and valid, in line with the provisions of laws, regulations and the articles of association.

2. Attendees and observers of the meeting

It has been verified that a total of 810 shareholders and authorized agents attended the general meeting of shareholders, and the representatives have a table

The total number of voting shares is 1345891908 shares, accounting for 48.9918% of the company's total share capital, of which 3 shareholders and authorized agents attended the on-site meeting, representing a total of 14,970 voting shares. Other persons attending the on-site meeting of the general meeting of shareholders are the company's directors, supervisors, senior managers and witness lawyers hired by the company.

The qualifications of shareholders who participate in voting through the online voting system have been certified by the voting system of Shanghai Stock Exchange Information Network Co., Ltd., and the qualifications of shareholders attending the meeting are legal and valid.

It has been verified that the actual time, place, method, proposals and other matters considered by the meeting are consistent with the notice of the meeting, and the notice and convening procedures of the meeting are in accordance with the relevant provisions of China's laws, regulations and normative documents and the Articles of Association, which are legal and valid.

3. Voting procedures and voting results of the general meeting of shareholders

The general meeting of shareholders adopts a combination of on-site voting and online voting

The following motions were deliberated and voted on one by one:

1. "Proposal on the Estimated Quota of Daily Related Party Transactions in 2025"

1.01 "Estimated Daily Connected Transactions with Jiangsu Xinhua Semiconductor Technology Co., Ltd. in 2025

Quota Motion";

1.02 "Proposal on the Estimated Quota of Daily Connected Transactions with Axcelis Technology in 2025";

1.03 "Proposal on the Estimated Quota of Daily Connected Transactions with Soitec in 2025";

1.04 "About the 2025 Routine Connected Transactions with China Micro Semiconductor Equipment (Shanghai) Co., Ltd

Proposal on the estimated amount";

1.05 "About the 2025 Annual Routine Relationship with Shanghai Integrated Circuit Equipment and Materials Industry Innovation Center Co., Ltd

Proposal on the estimated quota of joint transactions";

1.06 "Estimated 2025 Daily Connected Transactions with Shanghai Institute of Integrated Circuit Materials Co., Ltd."

Quota Motion";

1.07 "On the estimated quota of daily related party transactions with Tianshui Huatian Technology Co., Ltd. in 2025

Motion";

1.08 "Discussion on the Estimated Quota of Daily Related Party Transactions with Shanghai New Micro Semiconductor Co., Ltd. in 2025".

case;

1.09 "On the estimated quota of daily related party transactions with Ningbo Nanda Optoelectronic Materials Co., Ltd. in 2025

Motion";

2. Proposal on the Proposed Signing of Procurement Framework Contracts and Related Party Transactions by Subsidiaries

3. Proposal on Providing Guarantee for Holding Subsidiaries

There is no special resolution for the above proposals, of which proposals 1 and 2 are counted separately for small and medium-sized investors; Motion 1.08

When it comes to the recusal of related shareholders from voting, the name of the related shareholders who should abstain from voting is Shanghai New Micro Technology Group Co., Ltd.

It has been verified that the voting process, exercise of voting rights and voting procedures of the company's general meeting of shareholders comply with laws, regulations, normative documents and the relevant provisions of the Articles of Association, and the voting results are legal and valid.

Fourth, the general meeting of shareholders did not put forward new temporary proposals

Concluding remarks

To sum up, our lawyers believe that the convening and convening procedures of the company's general meeting of shareholders comply with the provisions of laws, regulations, normative documents and the Articles of Association; The qualifications of the convener of this meeting are legal and valid; The qualifications of the persons attending the general meeting of shareholders are legal and valid; The voting procedures and voting results are legal and valid.

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