Atlas Asset Management · ZISIF §15

About
us

REGISTERED §15 ZISIF ENTITY · CZ
QUALIFIED INVESTORS ONLY
LONG-ONLY EQUITY · CONCENTRATED
BENCHMARK MSCI EM SMID (EEMS)
Who we are
In one paragraph

Atlas Asset Management is a Czech investment manager registered as a §15 ZISIF entity (osoba rizikového kapitálu) with the Czech National Bank. We manage two long-only equity vehicles for qualified investors: the flagship Atlas AM ZISIF15 vehicle and a portfolio managed on behalf of Klub Investorů (KI AM). Both vehicles share the same investment philosophy — concentrated positions, multi-year horizons, and capital preservation through quality rather than diversification or hedging.

We do not run a hedge fund, we do not use leverage, and we do not short. We compound capital by buying a small number of high-quality equity stories at sensible prices and holding them through cycles. The work is fundamental — reading filings, building conviction, and waiting.

At a glance
Legal entitys.r.o.
Regulatory statusZISIF §15
SupervisorCNB list (not supervised)
Investor basequalified investors
Vehicles managed2 (ZISIF15 + KI AM)
Stylelong-only · concentrated
Reporting cadencequarterly to investors
What is ZISIF §15?
Regulatory framing

"ZISIF" is the Czech Act on Investment Companies and Investment Funds (Act No. 240/2013 Coll.). Section 15 of the Act establishes a category of "registered persons" — managers who fall below the AIFMD authorization thresholds and instead operate under a lighter registration regime maintained by the Czech National Bank.

An entity registered under §15 is a recognised collective-investment manager whose activities are recorded by the Czech National Bank, but whose operations are not subject to ongoing supervision by the CNB. The trade-off is intentional: the regime is reserved for managers serving exclusively qualified investors, who bring their own due-diligence capacity rather than relying on regulatory oversight.

What it means for investors
1
Qualified investors only
Access is restricted by law to qualified investors as defined under ZISIF — institutional investors and individuals who meet the statutory wealth and experience tests.
2
Transparent legal status
Atlas AM is publicly listed in the §15 register maintained by the Czech National Bank. Verification is one query away.
3
Investor-led due diligence
Because the CNB does not supervise §15 entities, qualified investors are expected to conduct their own diligence on strategy, risk, governance and reporting.
4
Lean operating model
The §15 framework keeps overhead low and decision-making concentrated, which fits a focused long-only mandate with a small number of holdings.
The §15 register is public. It is not a fund authorisation; it is a registration. Investment is intended exclusively for qualified investors.
Investment philosophy
First principle

Concentrate.

Returns come from a small number of correct decisions sized properly. We hold 15–25 positions, with a hard cap of 10% per name at cost. Diversification past that point dilutes thinking, not risk.

Second principle

Compound.

The investment horizon is years, not quarters. We size positions for a 3–7 year hold and exit only when the original thesis is wrong, fully priced, or replaced by a better opportunity.

Third principle

Stay liquid.

A permanent 10% cash floor sits behind the portfolio. Cash is treated as a position, not a residue — the option to act when the market mis-prices a known holding is worth more than the optical drag of an empty week.

Two vehicles · one methodology
Vehicle I · Atlas AM ZISIF15

The flagship investment vehicle administered by Atlas Asset Management as a §15 registered person. Concentrated long-only equity portfolio combining SMID compounders, emerging-markets exposure and selective equity stories. Open exclusively to qualified investors under Czech ZISIF law.

Reporting to investors is quarterly, with a semi-annual mandate review.

qualified investors long-only concentrated
Vehicle II · KI AM

Portfolio managed by Atlas Asset Management on behalf of Klub Investorů (KI). The same investment philosophy and rules of engagement as the ZISIF15 vehicle apply — concentrated, long-only, fundamentals-led.

Allocation, risk limits and reporting are governed by the client mandate. The methodology — universe definition, position sizing, exit rules — is identical to the ZISIF15 vehicle.

managed mandate long-only shared methodology

"Concentration with conviction. Years, not quarters. Cash is a position, not a residue. Few decisions, sized correctly, held long enough to matter."

— Atlas Asset Management · house principles