Zip Code: 100005

Telephone:(86-10) 8519-1300

Fax:(86-10) 8519-1350

junhebj@junhe.com

Beijing Junhe Law Firm

About

Beijing Kingsoft Office Software Co., Ltd.

Differentiated rights and interests distribution matters

Yes

Legal Opinion

June 2024

About Beijing Kingsoft Office Software Co., Ltd

Differentiated rights and interests distribution matters

of legal opinion

To: Beijing Kingsoft Office Software Co., Ltd.

Beijing Junhe Law firm (hereinafter referred to as "the firm") is entrusted by Beijing Jinshan Office Software Co., Ltd. (hereinafter referred to as "the company", "listed company" or "Jinshan Office") to act as the special legal adviser for the distribution of differentiated rights and interests involved in the profit distribution of Jinshan Office in 2023 (hereinafter referred to as "this differentiated rights and interests distribution"), in accordance with the Company Law of the the People's Republic of China (hereinafter referred to as the Company Law), the Securities Law of the the People's Republic of China (hereinafter referred to as the Securities Law), the self-regulatory guidelines for listed companies of the Shanghai Stock Exchange No. 7-share repurchase and the People's Republic of China (including the Hong Kong Special Administrative region, the Macao Special Administrative region and Taiwan, for the purpose of this legal opinion only, specifically within the territory of China, hereinafter referred to as "China") other relevant laws, regulations and normative documents, and the relevant provisions of the "Articles of Association of Beijing Jinshan Office Software Co., Ltd." (hereinafter referred to as the "Articles of Association"), this legal opinion is issued on this differentiated rights and interests distribution.

In order to issue this legal opinion, our lawyers verified the relevant facts involved in the distribution of differentiated rights and interests, and inquired relevant personnel and conducted necessary discussions on relevant matters.

In order to ensure the authenticity, accuracy and legality of the relevant conclusions of the legal opinion, our lawyers have reviewed the documents and materials related to the issuance of this legal opinion, and rely on the following guarantee from Jinshan Office: Jinshan Office has provided the necessary and true original written materials, duplicate materials, photocopied materials or oral testimony for the issuance of this legal opinion, without any omission, concealment, falsehood or misleading, and these documents and oral testimony have not undergone any changes on the date they are provided to the Exchange and the date of issuance of this legal opinion; if the documents are copies or photocopies, their contents are consistent with the original or original; submitted to the Exchange All the signatories of the documents have full capacity for civil conduct, and their signing behavior has been properly and effectively authorized.

For the facts that the firm cannot independently verify, the lawyers of the firm rely on relevant certificates and explanatory documents issued by relevant government departments, Jinshan Office and other relevant parties.

In this legal opinion, our lawyers only express legal opinions on important legal issues that have occurred or existed before the date of this legal opinion and are related to the distribution of differentiated rights and interests, and do not express opinions on other issues and professional matters such as accounting and auditing. This legal opinion is issued in accordance with the laws of the People's Republic of China and is limited to the laws of the People's Republic of China that have been published and are currently in force prior to the issuance of this legal opinion. This legal opinion does not

To express opinions on matters relating to foreign law or the application of foreign law. The quotation of the contents of accounting, auditing and other professional documents (including but not limited to audit reports, etc.) by our lawyers in this legal opinion does not mean that our lawyers make any express or implied guarantee of the authenticity and accuracy of these professional documents and the quoted contents, nor do our lawyers have the professional qualifications to verify and judge these professional documents and the quoted contents.

In accordance with the provisions of the Securities Law, the measures for the Administration of Securities legal Business of Law firms and the rules for the practice of Securities legal Business of Law firms (for trial implementation), and the facts that have occurred or existed before the date of this legal opinion, the firm and its lawyers have strictly performed their legal duties, followed the principles of diligence, due diligence and good faith, and carried out full verification and verification, ensure that the domestic facts identified in this legal opinion are true, accurate and complete, that the concluding opinions issued are legal and accurate, and that there are no false records, misleading statements or material omissions, and bear the corresponding legal liability.

This legal opinion is only for the use of Jinshan Office for the purpose of this differentiated equity distribution and shall not be used for any other purpose. Our lawyers agree to disclose this legal opinion as a necessary statutory document for the distribution of differentiated rights and interests together with other materials. The Firm agrees that Jinshan Office shall quote some or all of the contents of this legal opinion in the relevant documents for the distribution of differential rights and interests, but Jinshan Office shall make such references in a comprehensive and accurate manner and shall not lead to errors or deviations in the understanding of this legal opinion.

Based on the above, in accordance with the requirements of relevant laws, regulations and regulatory documents, and in accordance with the business standards, ethics and diligence recognized by the Chinese lawyer industry, the Firm issues this legal opinion as follows:

1. reasons and basis for this differentiated equity distribution

According to the company's relevant announcement, on January 31, 2024, the company held the 15th meeting of the third board of directors.

At the meeting, the "Proposal on the Repurchase of the Company's Shares by Centralized Auction Transaction" was reviewed and approved, and the company agreed to repurchase the company's issued RMB ordinary shares (A shares) through centralized bidding transactions. The repurchase price does not exceed RMB 380 per share (inclusive), and the total amount of funds for the repurchase of shares is not less than RMB 50 million (inclusive) and not more than RMB 100 million (inclusive). The repurchased shares will all be used to implement the employee stock ownership plan and equity incentive plan, and will be used within 3 years after the company discloses the results of the implementation of the share repurchase and the announcement of the share change. The repurchase period is 12 months from the date of consideration and approval of the share repurchase plan by the Board of Directors.

According to the documents and instructions provided by the company, as of May 31, 2024, the company through the Shanghai Securities Exchange.

The trading system has repurchased a total of 138,688 shares of the Company by means of centralized bidding, accounting for 0.03 of 462,057,980 shares of the Company's total share capital.

In accordance with the provisions of the Company Law, the Securities Law, the Self-Regulatory Guidelines for Listed Companies of the Shanghai Stock Exchange No. 7-Repurchase of Shares and the Articles of Association of the Company, the shares repurchased by the above-mentioned companies do not enjoy the right to profit distribution. Therefore, the company's 2023 profit distribution to implement differentiated equity distribution.

Accordingly, the lawyers of the firm have verified that the company's differentiated equity distribution belongs to the shares that have been repurchased to the special account and does not participate in the distribution, which is in compliance with the Company Law, the Securities Law, and the Self-Regulatory Guidelines for Listed Companies of the Shanghai Stock Exchange No. 7-Repurchase of Shares "and the" Articles of Association.

2. scheme for this differentiated equity distribution

According to the documents and instructions provided by the company, on May 28, 2024, the company's annual shareholder stake in 2023

The meeting considered and passed the "Proposal on the Company's Profit Distribution Plan for 2023".

According to the Company's "Jinshan Office 2023 Annual Profit Distribution Plan" disclosed on March 21, 2024

(Announcement No. 2024-016), the Company intends to pay a cash dividend of 8.8 to all shareholders for every 10 shares.

Yuan (including tax). As of March 20, 2024, the Company's total share capital was 461,817,245 shares, with special certificates for repurchase.

The total number of shares in the securities account is 122,068 shares, which is used to calculate the total proposed bonus of 406,291,755.76 yuan (including tax). The shares in the Company's repurchase of the special securities account will not participate in the Company's profit distribution. If the total share capital of the company changes due to convertible bond conversion, share repurchase, share repurchase and cancellation of share repurchase granted by equity incentive, share repurchase and cancellation of major asset restructuring shares, etc. during the period from the date of disclosure of the announcement to the date of implementation of equity distribution, the total share capital of the equity registration date of the future implementation of the distribution plan shall be deducted from the number of shares in the special securities account for repurchase, the amount of distribution per share and the total number of shares transferred will be adjusted accordingly, and the specific adjustment will be announced separately.

According to the Company's disclosure on June 1, 2024, "Jinshan Office on Adjusting the Profit Distribution for 2023"

Announcement of the Amount of Dividend Per Share of the Scheme (Announcement No. 2024-042), the registration of shares for the second vesting period of the first grant of partial Class I incentive objects under the Company's 2022 Restricted Stock Incentive Plan has been completed, and the public

The company added 240,735 shares, and on May 28, 2024, it was listed in China Securities Depository and Clearing Co., Ltd.

The Shanghai branch of the company has completed the registration procedures for the new shares, and the total share capital of the company has been increased from 461,817,245 shares.

Add to 462,057,980 shares. As of May 31, 2024, the Company traded through the Shanghai Stock Exchange.

The Company has repurchased 138,688 shares of the Company by means of centralized bidding. Based on the above-mentioned changes in total share capital, the company will adjust the per share ratio of the 2023 profit distribution plan in accordance with the principle of maintaining the total distribution unchanged, and determine to distribute a cash dividend of 8.7957 yuan (tax included) for every 10 shares, and a cash dividend per share. 0.87957 yuan (tax included, keep 5 decimal places).

3. the calculation of the ex-dividend scheme for this differentiated equity distribution

According to the documents and instructions provided by the Company, in accordance with the trading day prior to the Company's application for differentiated equity distribution (I. e.

May 31, 2024) The closing price of the company's stock is 258.80 yuan/share to calculate the ex-dividend (dividend) reference price,

The impact of this differentiated equity sub-party on the ex-dividend reference price is measured as follows:

1. According to the company's 2023 profit distribution plan, the actual cash dividend per share distributed by the company this time is 0.87957 yuan/share (including tax); the company only distributes cash dividends this time, and does not send shares or convert capital reserve into share capital. Therefore, the company's circulating shares will not change, and the change ratio of circulating shares is 0.

2. As a result of the Company's differentiated equity distribution, the proportion of cash dividends and changes in outstanding shares in the formula for calculating the ex-rights and ex-dividend reference price according to the virtual distribution refers to the proportion of cash dividends per share and changes in outstanding shares calculated after the actual distribution is adjusted according to the dilution of the total share capital.

Virtual cash dividends per share = (total share capital involved in distribution x cash dividends per share actually distributed) ÷ total share capital =(461,919,292 x 0.87957)÷ 462,057,980 ≈ $0.8793;

3. Therefore, according to the trading day before the company's application for differentiated equity distribution (I. e., May 31, 2024)

Closing price 258.80 yuan/share testCalculate:

(1) Ex-rights and ex-dividend reference price based on actual distribution = (previous closing price-cash dividends) ÷(1 + percentage change in outstanding shares) =(258.80-0.87957)÷(1+0)≈ $257.92043 per share;

(2) Ex-rights and ex-dividend reference price based on virtual distribution = (previous closing price-cash dividend) ÷(1 + percentage change in outstanding shares) =(258.80-0.8793)÷(1+0)≈ $257.9207 per share;

(3) Ex-right and ex-dividend reference price impact = | Ex-right and ex-dividend reference price calculated based on actual distribution-Ex-right and ex-dividend reference price calculated based on virtual distribution | ÷ Ex-right and ex-dividend reference price calculated based on actual distribution = | 257.92043-257.9207 | ÷ 257.92043 ≈ 0.0001%.

Accordingly, as verified by our lawyers, the receipt of the transaction date prior to the application date (I. e., May 31, 2024) is as follows

The price of 258.80 yuan/share calculation, the absolute value of the impact of this differentiated equity sub-party on the ex-dividend reference price is less than 1%.

4. concluding comments

In summary, our lawyers believe that the company's differentiated rights and interests distribution is in compliance with the Company Law, the Securities Law, the Shanghai Stock Exchange Listed Companies Self-Regulatory Guidelines No. 7-Repurchase of Shares and the Articles of Association. According to the regulations, there is no situation that harms the interests of listed companies and all shareholders.

(No text below)

2024 6 3