Core Viewpoint - The independent financial advisor, China International Capital Corporation (CICC), conducted a review of insider trading activities related to the major asset acquisition and related party transactions of Xin'ao Natural Gas Co., Ltd. The review found no direct evidence of insider trading among the identified insiders during the self-examination period, indicating that their trading activities do not pose substantial legal obstacles to the transaction [1][13]. Group 1: Insider Trading Review - The self-examination period for insider trading activities spans from September 19, 2024, to April 25, 2025, which is six months prior to the suspension of trading and one day before the disclosure of the restructuring report [1]. - The review included senior management and other relevant personnel involved in the transaction [2]. - The review identified specific trading activities of individuals within the insider group, detailing their cumulative buy and sell transactions during the self-examination period [2][3]. Group 2: Individual Commitments - Each insider provided a commitment stating that their trading activities were based on personal judgment of market conditions and did not involve insider information [4][5][6]. - Insiders confirmed they were unaware of the restructuring details prior to specific dates, ensuring their trading actions were not influenced by undisclosed information [4][5][6]. - The commitments included assurances against leaking insider information or engaging in prohibited trading behaviors [4][5][6]. Group 3: Institutional Trading Activities - CICC reported its trading activities in Xin'ao shares, asserting compliance with legal regulations and internal information barriers to prevent insider trading [9][10]. - The firm emphasized that its trading decisions were based on independent investment research and were not related to the restructuring [10][12]. - CICC committed to adhering to relevant laws and regulations until the completion or termination of the restructuring [10][12]. Group 4: Conclusion of the Review - The independent financial advisor concluded that there was no direct evidence of insider trading among the identified insiders during the self-examination period, and the trading activities did not constitute a legal barrier to the transaction [13].

中国北京市西城区金融大街 5 号 新盛大厦 B 座 19 层 邮编：100032 Tel：+86 10 66578066 Fax：+86 10 66578016 19/F, Tower B, Xinsheng Plaza, No.5 http：// www.guantao.com 100032, China E-mail：guantao@guantao.com Finance Street, Xicheng District, Beijing 观意字 2025BJ000942 号 北京观韬律师事务所 专项核查意见 观意字 2025BJ000942 号 北京观韬律师事务所（以下简称"本所"）受山东阳谷华泰化工股份有限公司（以 下简称"阳谷华泰"、"上市公司"或"公司"）委托，担任阳谷华泰发行股份及支 付现金购买波米科技有限公司（以下简称"波米科技"或"标的公司"）全部 100% 股权并募集配套资金暨关联交易（以下简称"本次交易"或"本次重组"）的专项法 律顾问。 本所律师根据相关法律法规的要求，按照律师行业公认的业务标准、道德规范 和勤勉尽责精神，出具专项核查意见如下： 一、核查期间 本次交易的内幕信息知情人买 ...