上海港湾: 北京市中伦律师事务所关于上海港湾基础建设（集团）股份有限公司差异化权益分派事项的法律意见书

Core Viewpoint - The legal opinion letter issued by Beijing Zhonglun Law Firm confirms that Shanghai Port Construction (Group) Co., Ltd.'s differentiated equity distribution plan for the 2024 profit distribution complies with relevant laws and regulations, ensuring no harm to the interests of the company and its shareholders [8][9]. Group 1: Differentiated Equity Distribution Plan - The company plans to distribute a cash dividend of 1.14 yuan (including tax) for every 10 shares held, based on the total share capital minus the shares held in the repurchase account [5][6]. - The total number of shares eligible for the distribution is 244,584,809 shares after excluding 32 shares held in the repurchase account [5][6]. - The total cash dividend to be distributed amounts to approximately 27.88 million yuan [6]. Group 2: Legal Compliance and Verification - The legal opinion is based on thorough verification of documents and facts related to the differentiated equity distribution, adhering to the principles of prudence and materiality [2][4]. - The opinion confirms that the distribution plan aligns with the Company Law, Securities Law, and other relevant regulations, ensuring the legality and accuracy of the conclusions drawn [8][9]. - The impact of the repurchased shares on the ex-dividend price is negligible, with an absolute value impact of less than 1% [7][8].