ADAMA Ltd.

     Independent Opinions on the Relevant Issues of the
        11th Meeting of the 8th Session of the Board of
                                    Directors

In accordance with the Company Law of the People’s Republic of China, Guidance on
Establishing the Independent Director System in Listed Companies, and other laws,
regulations and normative documents, as well as the Articles of Association and
Independent Director System, we, as the independent directors of Hubei Sanonda Co.,
Ltd.(hereinafter referred to as “Company”), give our independent opinions on the
relevant proposals of the 11th Meeting of the 8th Session of the Board of Directors
from the standpoint of independent judgment:


1.    Independent Opinions on the Expected Related Party Transactions in the
      Ordinary Course of Business in 2019


(1) The transactions between related parties that have occurred in 2018 are all needed
     by the normal and daily operation of the Company. All the transactions were
     conducted in line with market practice and the laws and regulations; They have
     served the Company's long-term interests and met requirement of development
     strategies. The gap between the actual amount and the estimation of the
     transactions between related parties in 2018, is a reasonable and proper result of
     the market conditions and the actual needs of the Company. Such gap will neither
     trigger any major impact on production and operation, nor harm the interests of
     the Company and its minority shareholders, as well as will not compromise the
     independency of the Company.




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(2) We have pre-approved the proposal on the Expected Related Party Transactions in
   the Ordinary Course of Business in 2019 before the meeting of the BOD. We are
   of the opinion that the related party transactions are the normal matters in the
   Company’s operation. We agree to submit this proposal to the BOD meeting.


  The related directors withdrew from the vote. This proposal has been passed by the
  non-related directors. The decision-making procedures for these related party
  transactions conform to the Company Law of the People’s Republic of China, the
  Rules of Shenzhen Stock Exchange for the Listing of Stocks, the Articles of
  Association and other laws and regulations.


  The Group's related-party transactions performed in the ordinary course of business
  are mainly to purchase or sell goods, materials and services from/to the related
  parties based on the principles of justice and fairness and the pricing standards
  consistent with those of non-related parties, in order to assist in capitalizing the
  Group’s unique positioning and profile, achieve cost savings, increase sales, market
  share and drive its profitable growth. All such transactions shall conform to
  relevant national laws and regulations, as applicable, and the market-oriented
  principles, and shall not influence the independence of the Company or damage the
  interests of the Company and its other shareholders. The decision-making
  procedures for these related party transactions conform to the Company Law of the
  People’s Republic of China, the Rules of Shenzhen Stock Exchange for the Listing
  of Stocks, the Articles of Association and other laws and regulations. We agree on
  this proposal and submit it to the General Meeting of Shareholders for deliberation.


2. Independent opinions on the Remuneration Policy for Senior Executives of the
 Company
 The Remuneration Policy for Senior Executives of the Company is based on the
 actual operation situations of the Company and is adjusted and determined upon the

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remuneration standard of other listed companies belonging to the same field and
same class of the Company as well as the regional development standard. The policy
helps to better attract and retain talents, to exert initiatives of the Company’s senior
executives and to promote the long-term sustainable development of the Company.
The policy complies with relevant laws, regulations and the Articles of Association
and will not harm the legal rights and interests of all the shareholders and investors.
Therefore, we agree to determine the remuneration of senior executives based on the
Remuneration Policy for Senior Executives of the Company.




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 (The signature page of Independent Opinions on the Relevant Issues of the 11th
Meeting of the 8th Session of the Board of Directors)

Independent Director Signature:




__________________                             ___________________

    Tang Yunwei                                       Xi Zhen




                                                             February 21, 2019




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