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广大特材: 安徽天禾律师事务所关于张家港广大特材股份有限公司差异化分红事项的法律意见书

Core Viewpoint - The legal opinion letter from Anhui Tianhe Law Firm confirms that Zhangjiagang Guoda Special Materials Co., Ltd. (Guoda Special Materials) is proceeding with a differentiated dividend distribution for the fiscal year 2024, in compliance with relevant laws and regulations [2][9]. Group 1: Differentiated Dividend Distribution - The differentiated dividend distribution is based on the company's decision to repurchase shares, which will not participate in profit distribution [5][8]. - The company plans to distribute a cash dividend of 3.75 RMB per 10 shares (including tax) to shareholders, with a total cash dividend amounting to approximately 76.48 million RMB (including tax) [5][6]. - The total share capital as of March 31, 2025, is 214,242,233 shares, with 10,306,697 shares in the repurchase account, resulting in an actual participating share capital of 203,935,536 shares [5][6]. Group 2: Share Repurchase and Legal Compliance - The company has approved a share repurchase plan using self-raised funds between 200 million RMB and 400 million RMB, with a maximum repurchase price of 26.22 RMB per share [4][5]. - The legal opinion confirms that the differentiated dividend distribution complies with the Company Law, Securities Law, and relevant regulations, ensuring no harm to the interests of the company and its shareholders [9]. - The impact of the differentiated dividend distribution on the ex-dividend reference price is minimal, with an absolute value change of less than 1% [7][8].