At the end of 2025, an announcement regarding the division of equity due to divorce involving Times-Creation Energy (Stock Code: 688429) triggered significant attention in the capital market. Over the past year, among the eleven divorce cases involving major shareholders of A-share listed companies, the majority of equity divisions faced challenges such as ambiguous subject matter, protracted processes, and difficulties in realizing equity interests. In contrast, in this specific division, the spouse of the actual controller successfully obtained equity interests with a market capitalization of 446 million RMB through a compliant planning path. This case avoided protracted disputes and achieved the rapid realization of property rights and interests, highlighting the core values of precision and efficiency in the division of marital property.

I. Precise Locking and Efficient Settlement of 446 Million RMB in Equity Interests

On December 30, 2025, Times-Creation Energy disclosed via announcement that the company's actual controller, Fu Liming, had dissolved his marriage with his spouse, and the two parties had reached a division agreement regarding the company equity held indirectly. According to the agreement, Fu Liming transferred, at no cost, his 10% equity interest in Nanjing Shichuang Venture Capital Co., Ltd. (referred to as Shichuang Investment) and his 14.48% property share in Nanjing Sicheng Venture Capital Partnership (referred to as Nanjing Sicheng) to the name of his spouse. The equity interests involved in this division correspond to approximately 34.1618 million shares of Times-Creation Energy, accounting for 8.54% of the company's total share capital. Based on the closing price of 13.07 RMB per share on the day of the announcement, the market capitalization of this portion of equity reached 446 million RMB.

It is worth noting that the entire division process achieved efficient implementation: the parties signed the Divorce Agreement through amicable negotiation without initiating judicial litigation procedures, thereby avoiding processes such as equity freezing and long-term trials. The compliant settlement was completed pursuant to the Implementing Rules for the Non-transaction Transfer of Securities of China Securities Depository and Clearing Corporation Limited, ensuring the timely realization of property rights and interests.

The core characteristic of this division lies in the clear definition of the subject matter, focusing on the property share in the shareholding platform rather than direct equity in the listed company. This approach not only circumvented the shareholder consent procedures required for the division of equity in a limited liability company but also avoided the impact of control disputes on the progress of the division, laying the foundation for the rapid realization of interests.

II. Paradigms for Equity Division Involving Spouses of Actual Controllers

In the A-share market, multiple cases of equity division involving the divorce of actual controllers have demonstrated the efficient logic of precisely defining the subject matter and selecting compliant paths, providing reference paradigms for similar situations.

The division case involving the spouse of the actual controller of Zhucheng Tech (301280) is highly representative. In the division of marital property, the spouse increased their shareholding ratio from 6.41% to 12.82% through the division of direct shareholdings, corresponding to a market capitalization of approximately 381 million RMB. The core operation lay in the parties clarifying the division plan in advance and relying on a signed long-term acting-in-concert agreement. This avoided procedural delays caused by disputes over control rights and enabled the completion of the settlement through non-transaction transfer, which not only secured the property share but also avoided the time and effort associated with judicial procedures.

The division model of the spouse of the actual controller of Zongheng Holdings (688070) is equally noteworthy. In that case, the spouse focused on the division of property shares in the indirect shareholding platform, ultimately obtaining 11.41% of the company's shares, with a market capitalization of approximately 537 million RMB. During the division process, the parties did not fall into the trap of fighting for control rights but instead took the realization of property interests as the core objective. After the court's final judgment clarified the shares, the non-transaction transfer was completed within one month, significantly shortening the division cycle.

In contrast to the case of Shanshui Tech (301190), where divorce led to a change in the actual controller and a change of the chairman, the common characteristic of these efficient cases is as follows: taking the realization of property interests as the core demand, precisely locking in the divisible equity interests, determining ownership through negotiation or efficient judicial procedures, and completing settlement via compliant transfer paths. This provides a clear practical paradigm for the equity division of the spouses of actual controllers.

III. Legal Basis

The efficient realization of equity division for the spouse of an actual controller is essentially the precise alignment of matrimonial and family law rules with capital market regulatory requirements. Its core operations are supported by explicit legal grounds.

(I) Application of Special Rules for the Division of Equity in Listed Companies

The division of equity in listed companies must balance the property interests of the couple with the intuitus personae nature of the company and the stability of the capital market. Article 3 of the Implementing Rules for the Non-transaction Transfer of Securities of China Securities Depository and Clearing Corporation Limited explicitly includes the division of property due to divorce as a legitimate circumstance for non-transaction transfer, providing the operational basis for this equity transfer.

The fact that the equity division of Times-Creation Energy did not trigger lengthy procedures is premised on the definition of the boundaries of the subject matter. By distinguishing the attribution of interests between direct shareholding and indirect shareholding, this case focused on the specific subject matter of property share in the shareholding platform rather than making a vague claim for company equity. This avoided disputes arising from ambiguous subject matter and provided a legal foundation for rapid division.

(II) Rules on Non-transaction Transfer: The Core Path for Efficient Realization of Interests

Article 7 of the Implementing Rules for the Non-transaction Transfer of Securities of China Securities Depository and Clearing Corporation Limited further stipulates that when handling non-transaction transfer for the division of property due to divorce, materials such as proof of dissolution of the marital relationship, an effective divorce agreement, and identity documents of both parties must be submitted.

This rule provides an efficient path for the equity division of the spouse of an actual controller: there is no need to trade through the secondary market, avoiding the impact of stock price fluctuations on property value, and no need to fulfill complex shareholder consent procedures. The Times-Creation Energy case relied precisely on this rule to complete the transfer quickly after reaching a consensus, confirming the core role of non-transaction transfer in efficient implementation and meeting the practical needs of marital property division.

(III) Alignment of Regulatory Compliance and Reduction Restrictions

According to Article 16 of the Interim Measures for the Administration of Reduction of Shareholding by Shareholders of Listed Companies (2025 Revision), where shares are distributed due to divorce, the transferor and the transferee of the shares shall continue to jointly abide by the provisions on shareholding reduction by major shareholders. The announcement of Times-Creation Energy explicitly disclosed that although the divided equity is within a lock-up period, the property interests of the spouse have been confirmed through share registration. The lock-up restriction applies only to trading circulation and does not affect the enjoyment of core interests such as dividends and appreciation.

At the same time, this case strictly avoided the regulatory red line of divorce-style reduction and complied with the requirements regarding the disclosure of the reduction quota distribution plan for shares divided upon divorce as stipulated in Guidelines No. 18 of the Shenzhen Stock Exchange for Self-Regulatory Supervision of Listed Companies, ensuring no circumvention of regulations occurred.

IV. Legal Operational Paths for Equity Division Upon Divorce

Combining the Times-Creation Energy case with years of practical experience, the efficient realization of equity interests for the spouse of an actual controller relies on a systematic legal operational path. It is necessary to build a complete operational system involving prior agreement establishment, adaptive path efficiency, and fallback for special circumstances, which can be advanced from the following three aspects:

(I) Prior Arrangement via Property Agreements and Acting-in-Concert Agreements

Contractual arrangement is the core foundation for the precision and efficiency of equity division, providing the legal basis for the realization of interests. The core lies in defining the attribution and exercise rules of equity interests through property agreements and acting-in-concert agreements. The property agreement should focus on the legal characterization of the equity subject matter, clearly defining the object of division, the proportion of interests, and the method of value realization, while also clarifying the attribution of derivative interests such as dividends and appreciation during the lock-up period to avoid subsequent disputes.

The stipulations of the acting-in-concert agreement must align with the characteristics of the equity structure and clarify the mode of exercising voting rights after division. This includes core content such as whether to maintain the acting-in-concert relationship and the scope and duration of the delegation of voting rights. This ensures the orderly exercise of equity interests, safeguarding the property interests of the spouse while avoiding the impact of voting rights disputes on the stability of corporate governance. The explicit stipulations in these two types of agreements provide a solid legal foundation for the settlement of interests.

Based on the rights boundaries defined by the agreements, it is necessary to further select a division path that is adapted to the equity form and regulatory requirements to achieve compliant and efficient settlement of interests.

(II) Division Paths with Compliance Adaptation and Efficiency Priority

The selection of the equity division path should follow the principles of compliance adaptation and efficiency priority, determining the optimal plan based on the form of equity holding and regulatory requirements. for indirect shareholding scenarios, priority should be given to the transfer of shares in the shareholding platform, relying on non-transaction transfer rules to achieve interest settlement. This not only aligns with the intuitus personae characteristics of limited liability companies but also simplifies the settlement process. For direct shareholding or scenarios unsuitable for share transfer, the method of value compensation can be adopted, determining the fair value of equity through professional valuation to guarantee the fair realization of property interests.

Regardless of the path chosen, it must conform to the statutory requirements for non-transaction transfer and the regulatory norms for the equity management of listed companies to ensure the compliance of the division act and avoid obstructions to the realization of interests due to improper path selection.

Furthermore, regarding special subject matters such as pre-IPO shares, a specific handling plan must be formulated in conjunction with lock-up rules to ensure the stable realization of interests.

(III) Special Regulations on the Handling of Restricted Shares

For restricted subject matters such as pre-IPO shares, the core of their division lies in clarifying the attribution of interests during the lock-up period and the realization path after the expiration of the lock-up period. According to regulatory rules, changes in shareholding caused by divorce division are not subject to annual transfer ratio restrictions; the restriction targets only the trading circulation link and does not affect the essential attribution of property interests.

In practice, rules for the distribution of earnings during the lock-up period can be clarified through agreements to ensure that the spouse legally enjoys interests such as dividends and appreciation. Simultaneously, the triggering conditions and specific methods for interest settlement after the expiration of the lock-up period can be agreed upon, or cash interests can be locked in advance through value compensation. This avoids the risk of equity value fluctuation during the lock-up period and achieves the compliant and stable realization of restricted equity interests.

Conclusion

The precise settlement and efficient implementation of the 446 million RMB equity interest in the Times-Creation Energy case provide a core lesson for the equity division of actual controllers upon divorce: the core of division lies in precisely defining the subject matter, selecting compliant paths, and focusing on the realization of interests, rather than engaging in a struggle for control.

In the division of marital property, the spouse of an actual controller needs to rely on matrimonial and family law and capital market regulatory rules. Through scientific agreement arrangements, adaptive path selection, and compliant handling of special circumstances, the rapid and compliant realization of property rights and interests can be achieved.

Would you like me to draft a summary checklist of the specific clauses that should be included in an "Acting-in-Concert Agreement" to protect both governance stability and the spouse's financial interests based on these principles?