3onedata(SH:688618) Zheng Quan Zhi Xing·2025-07-29 16:12Core Viewpoint - The legal opinion letter from Shanghai Junlan Law Firm confirms that Shenzhen Sanwang Communication Co., Ltd. is qualified to implement its 2025 Employee Stock Ownership Plan (ESOP) and that the plan complies with relevant regulations and has undergone necessary legal procedures [1][5][16]. Group 1: Company Qualifications - Shenzhen Sanwang Communication was established as a joint-stock company through the overall change of Shenzhen Sanwang Communication Technology Co., Ltd. on January 29, 2019 [3]. - The company is legally established and in good standing, with no circumstances requiring termination under applicable laws and regulations [5]. Group 2: Legality and Compliance of the ESOP - The ESOP has been approved by the company's third employee representative assembly and relevant board meetings, ensuring compliance with the Trial Guidance and Regulatory Guidelines [6][10]. - The plan adheres to principles of voluntary participation, with no forced participation of employees [6][8]. - Participants in the ESOP will bear their own risks and have equal rights with other investors [6][8]. Group 3: ESOP Structure and Management - The ESOP will include up to 60 participants, primarily consisting of directors (excluding independent directors), senior management, and key technical and business personnel [7][9]. - The funding for the ESOP will come from employees' legal salaries, performance bonuses, or other legally permitted sources [7][8]. - The stock for the ESOP will be acquired through legal means in the secondary market, with a completion deadline of six months post-approval [7][8]. Group 4: Legal Procedures and Information Disclosure - The company has completed necessary legal procedures, including board approvals and committee reviews, and is awaiting shareholder meeting approval for the ESOP [12][14]. - The company has fulfilled initial information disclosure obligations and will continue to disclose relevant information as required by regulations [15][16]. Group 5: Conclusion - The legal opinion concludes that the company is qualified to implement the ESOP, which complies with relevant regulations and has undergone necessary legal procedures, pending shareholder approval for implementation [16].