法本信息: 北京市君泽君（上海）律师事务所关于深圳市法本信息技术股份有限公司2025年员工持股计划（草案）之法律意见书

Core Viewpoint - The legal opinion letter from Beijing Junzejun (Shanghai) Law Firm confirms the legality and compliance of Shenzhen Fabon Information Technology Co., Ltd.'s 2025 Employee Stock Ownership Plan (ESOP) draft, stating that the company meets the necessary qualifications and has followed the required procedures for implementation [4][10][16]. Group 1: Company Overview - Shenzhen Fabon Information Technology Co., Ltd. was established on November 8, 2006, with a registered capital of RMB 4,287.08945 million [5]. - The company is engaged in various business activities, including software development, internet software technology services, and data processing services [5][6]. Group 2: Employee Stock Ownership Plan (ESOP) Details - The ESOP draft allows for a maximum of 136.79 million shares to be allocated, representing approximately 0.32% of the company's total share capital of 4,287.089 million shares [9]. - The plan will be funded through a special reward fund and other legally permitted means, without involving leveraged funds or third-party financial support [9][10]. Group 3: Compliance and Legal Procedures - The company has conducted necessary internal reviews and obtained approvals from the board of directors and the supervisory board regarding the ESOP [10][13]. - The ESOP has been structured to ensure voluntary participation from employees, with no forced allocation of shares [7][9]. Group 4: Voting and Decision-Making - The company will hold a shareholders' meeting to vote on the ESOP, ensuring that related parties abstain from voting to maintain compliance with regulations [13][14]. - The management committee will oversee the ESOP, ensuring that it operates independently from the company's controlling shareholders and management [15]. Group 5: Information Disclosure - The company has fulfilled its information disclosure obligations related to the ESOP, and will continue to comply with relevant regulations as the plan progresses [16].