FANGDAPARTNERS

http://www.fangdalaw.com

No. 288, Shimen 1st Road, Shanghai, China E-mail: email@fangdalaw.com

HKRI Taikoo Hui, 24/F, HKRI Centre Tower 2 Tel.: 86-21-2208-1166

Postal code: 200041 Fax: 86-21-5298-5599

24/F, HKRI Centre Two

HKRI Taikoo Hui

288 Shi Men Yi Road

Shanghai 200041, PRC

Shanghai Fangda Law Firm

About Xinjiang Daqo New Energy Co., Ltd

Legal opinion for the 2024 Second Extraordinary General Meeting of Shareholders

To: Xinjiang Daqo New Energy Co., Ltd

Shanghai Fangda Law Firm (hereinafter referred to as the "Firm") is a law firm with legal practice qualifications in the People's Republic of China. In accordance with the relevant legal counsel agreement, the firm appointed a lawyer to attend the second extraordinary general meeting of shareholders of Xinjiang Daqo New Energy Co., Ltd. (hereinafter referred to as the "Company") in 2024 (hereinafter referred to as the "General Meeting of Shareholders"), and issued this legal opinion on the convening and convening procedures of the General Meeting of Shareholders, the qualifications of the persons participating in the voting and convening of the meeting, the voting procedures and voting results.

This legal opinion is based on the Company Law of the People's Republic of China, the Securities Law of the People's Republic of China, the Rules of the General Meeting of Shareholders of Listed Companies and other relevant laws, regulations, rules and normative documents that have been publicly promulgated and taken effect within the territory of the People's Republic of China (hereinafter collectively referred to as "PRC laws and regulations", which are only for the purpose of this legal opinion, excluding the laws and regulations of the Hong Kong Special Administrative Region of China, the Macao Special Administrative Region of China and the Taiwan region of China) and the Articles of Association of Xinjiang Daqo New Energy Co., Ltd. (hereinafter referred to as the "Articles of Association").

This legal opinion only expresses opinions on whether the convening and convening procedures of the general meeting of shareholders, the persons attending the meeting, the conveners, and the voting procedures comply with the relevant Chinese laws and regulations and the Articles of Association, as well as whether the voting results are legal and valid, and does not express any opinions on the laws of any country or region other than the laws and regulations of the People's Republic of China. This legal opinion is issued on the assumption that: (1) the original and copies of all documents provided by the company

This book is true, accurate and complete; (2) The company has disclosed to the firm all facts and documents that are sufficient to affect the issuance of this legal opinion, and there is no concealment or omission.

In accordance with the provisions of the Securities Law of the People's Republic of China, the Administrative Measures for Law Firms Engaging in Securities Legal Business, and the Practice Rules for Securities Legal Business of Law Firms (for Trial Implementation), as well as the facts that have occurred or existed before the date of issuance of this legal opinion, the firm and its assigned lawyers have strictly performed their statutory duties, followed the principles of diligence and good faith, and conducted sufficient verification and verification to ensure that the facts identified in this legal opinion are true, accurate and complete, and the conclusive opinions issued are legal and accurate. There are no false records, misleading statements or major omissions, and the corresponding legal responsibilities are assumed.

This legal opinion is for the Company's use only for the purpose of this General Meeting of Shareholders. This legal opinion may not be provided to, relied upon by, or used for any other purpose by any third party without the prior written consent of the firm. The lawyer of the firm agrees to announce this legal opinion in accordance with the relevant provisions of the resolution of the general meeting of shareholders.

In accordance with the requirements of the current effective Chinese laws and regulations, and in accordance with the generally recognized professional standards, ethics and diligence of the Chinese lawyer industry, our lawyers issue legal opinions on the subject matter as follows:

1. On the convening and convening procedures of the general meeting of shareholders

After verification by the lawyer of the firm, the board of directors of the company issued a report on the convening of Xinjiang Daqo New Energy Co., Ltd

The Notice of the Second Extraordinary General Meeting of Shareholders in 2024 was published on the Shanghai Stock Exchange on November 23, 2024

E-Exchange website (www.sse.com.cn) and media that meet the conditions stipulated by the China Securities Regulatory Commission.

The general meeting of shareholders was held by a combination of on-site voting and online voting, and the on-site meeting was held

Tuesday, December 10, 2024 at 14:30 p.m. at 838 Zhangyang Road, Pudong New Area, Shanghai

The conference room of Block A/J on the 29th floor of Huadu Building was held, and the online voting time is: the time for online voting through the trading system of the Shanghai Stock Exchange is the trading time period on the day of the general meeting of shareholders, that is, in 2024

December 10, 9:15 a.m. to 9:25 a.m., 9:30 a.m. to 11:30 p.m., and 13:00 to 15:00 p.m., via the Internet

The voting system will conduct online voting on the day of the general meeting of shareholders (December 10, 2024)

Any time between 9:15 a.m. and 15:00 p.m.

According to the company's announcement on November 23, 2024, Xinjiang Daqo New Energy Co., Ltd

Notice of convening the second extraordinary general meeting of shareholders in 2024, the announcement date of the notice of this general meeting of shareholders

The date of the general meeting of shareholders has reached the 15th, which is in accordance with the provisions of Chinese laws and regulations, and also in accordance with the Articles of Association.

The firm believes that the convening and convening procedures of this general meeting of shareholders are in accordance with the laws and regulations of the People's Republic of China and the Articles of Association.

2. Qualifications for voting and convening general meetings

According to the verification of our lawyers, a total of 5 shareholders (including shareholders' representatives) participated in the on-site voting of the company's shareholders' meeting, representing a total of 1,608,750,000 shares, accounting for 75.3544% of the company's total voting shares. According to the combined results of online voting and on-site voting provided by SSE Information Network Co., Ltd., a total of 345 shareholders (including shareholders' representatives) participated in the on-site voting and online voting at the company's second extraordinary general meeting of shareholders in 2024, representing a total of 1,626,330,905 voting shares, accounting for 76.1779% of the company's total voting shares. As verified by our lawyers, the qualifications of shareholders (including shareholders' representatives) attending the on-site meeting of the shareholders' meeting comply with the provisions of Chinese laws and regulations and the Articles of Association; The qualifications of shareholders who vote through the online voting system shall be verified by the Shanghai Stock Exchange Information Network Co., Ltd., the provider of the online voting system.

The convener of this general meeting of shareholders is the board of directors of the company, and in accordance with the provisions of Chinese laws and regulations and the provisions of the articles of association, the board of directors has the right to convene this general meeting of shareholders. In addition to the shareholders and shareholders' representatives who attended the shareholders' meeting, the directors, supervisors and senior managers of the company also attended or attended the shareholders' meeting.

The firm believes that the qualifications of the persons participating in the voting of this general meeting of shareholders are legal and valid, and the qualifications of the convener of this general meeting of shareholders are legal and valid.

3. Voting procedures and voting results of the general meeting of shareholders

(1) The voting procedures of the general meeting of shareholders

After verification by the lawyers of the firm, the general meeting of shareholders adopted a combination of on-site voting and online voting to consider the following proposals:

Motion 1: "Regarding the re-appointment of Deloitte Touche Tohmatsu Certified Public Accountants (Special General Partnership) as the company in 2024

Motion of the auditor

Motion 2.00: "Proposal on the By-election of Non-Independent Directors of the Third Board of Directors of the Company"

Proposal 2.01: "Proposal on By-election of Mr. Zhu Wengang as a Non-Independent Director of the Third Board of Directors of the Company"

Proposal 2 of this general meeting of shareholders is a cumulative voting proposal, and the company has adopted a cumulative voting system for voting.

Proposals 1 and 2 of this general meeting of shareholders are proposals for the separate counting of votes for small and medium-sized investors, and the company has agreed

The votes of small and medium-sized investors are counted separately.

After the on-site voting, the company's shareholder representatives, supervisors and lawyers of the firm counted and scrutinized the votes. After the voting of the shareholders' meeting, the company obtained the final voting results based on the statistical results provided by the Shanghai Stock Exchange Information Network Co., Ltd.

(2) The voting results of the general meeting of shareholders

After verification by our lawyers, the voting on the deliberation of the general meeting of shareholders is as follows:

Proposal 1 of this general meeting of shareholders has been voted and passed by ordinary resolution procedure at this general meeting of shareholders, that is, the number of voting shares that agree to the proposal has reached more than half of the total number of voting shares held by the shareholders of the company (including shareholders' representatives) attending the general meeting of shareholders.

Proposal 2 of this general meeting of shareholders has been voted on by ordinary resolution procedure and by cumulative voting system at this general meeting of shareholders, and according to the voting results of the cumulative voting system, the candidates under proposal 2 are elected.

In summary, the firm believes that the voting procedures and voting results of this general meeting of shareholders are in accordance with the provisions of Chinese laws and regulations, as well as the Articles of Association, and the voting procedures and voting results of this general meeting of shareholders are legal and valid. IV. Conclusions

In summary, the firm believes that the convening and convening procedures of this general meeting of shareholders comply with the relevant Chinese laws and regulations and the Articles of Association; The qualifications of the personnel participating in the voting of this general meeting of shareholders are legal and valid; The qualifications of the convener of this general meeting of shareholders are legal and valid; The voting procedures and voting results of this general meeting of shareholders are legal and valid.

Two originals of this legal opinion.

(No text below)