Atlantis Investment Management Limited

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Atlantis Investment Management Limited
CRD #155341
SEC #801-71944
CIK #
AUM
Employees 17 (47% Investors, 0% Brokers)
Fees
Minimum
Phone01185221106320
Address35/F, The Centrium, 60 Wyndham Street,Central
Hong Kong, Hong Kong
Source [IAPD] [Website]
Total AUM ($B)
4.03.22.41.60.80.02010201520202025
Fees and Compensation — Form ADV Part 2A (5/30/2019) [Brochure]
Fees and Compensation

Fees payable by each Fund are described in the applicable Fund offering document. Generally,
each Fund pays a management fee that ranges between 1% and 2% per annum of assets under
management, depending on the share class or series of the Fund and the amount invested. Fees
are typically paid monthly in arrears. Certain of the Funds also pay an annual performance-based
fee, which ranges between 15% and 20% of net realized and unrealized gains.

Atlantis may waive or rebate fees for certain investors, including for those investors who are
Company employees or affiliates or who may be large or strategic investors. Additionally, where
permitted to do so by a Fund’s governing documents or structure, Atlantis may, in limited
circumstances, enter into side letter arrangements with investors granting an investor preferred
economic investment terms.

In addition to the management and performance fees discussed above, the Funds are
responsible for the payment of administration, brokerage, and custodial fees, as well as their
own operating costs. Such costs include those relating to, among other things: (1) the charges
and expenses of legal advisers, auditors, and consultants; (2) borrowing and trading costs; (3)
taxes and corporate fees payable to governments or agencies; (4) directors’ fees; (5) preparing,
printing, and distributing financial and other reports; and (6) insurance.

Subject to prior authorization and its other policies and procedures, an employee, officer or a
director of Atlantis may receive compensation for serving on the board of a publicly traded
company in which Clients’ assets are invested by Atlantis. For more information on Atlantis’s
policies and procedures in this regard, see below under “Directorships and Outside Business
Activities”. Otherwise, neither Atlantis nor any of its related persons generally receive any
additional compensation in respect of Client assets that are invested in securities or other
investment products.

A complete description of fees and expenses applicable to each Fund is available in Fund
offering documents.

Institutional Clients pay an asset-based management fee, which varies based on factors including
the services provided, the size of the account and the entire relationship with the Institutional
Client, the investment mandate, and whether or not the Client also pays a performance-based
fee. Management fees are typically billed quarterly in arrears. Certain Institutional Clients may
also pay a performance-based fee on net realized and unrealized gains, billed annually in arrears.
Atlantis does not directly debit fees from Institutional Clients’ accounts. Rather, such Clients
receive an invoice each quarter showing how their fees were calculated. It is the responsibility of
the Institutional Client to remit fees to the Company. Fees for Institutional Clients are negotiable.

All Clients will incur brokerage and other transaction costs. Please refer to the “Brokerage
Practices” section below for additional information.

Performance-Based Fees and Side-by-Side Management

Performance-based fees may create an incentive for Atlantis to make investments that are
riskier or more speculative than would be the case in the absence of a performance fee. Since
the performance fees charged to each Client are based on both realized and unrealized gains,
the Company may receive a performance allocation reflecting unrealized gains at the end of a
period that are not subsequently recognized by the Client. Atlantis manages accounts that are
charged a performance-based fee, as well as accounts that pay only an asset-based management
fee. As such, Atlantis may have an incentive to favor certain Clients from which the Company
receives a performance fee over Clients that pay a lower or no performance fee. Atlantis has
procedures designed to ensure that all Clients are treated fairly and equally, and to prevent this
type of conflict from influencing the allocation of investment opportunities among Clients.
Account Minimums and Types of Clients — Form ADV Part 2A (5/30/2019) [Brochure]
Types of Clients

Atlantis provides investment advisory services in accordance with its Clients’ mandates. These
Clients may include, but are not limited to: collective investment vehicles, investment
companies, corporations, sovereign funds, other large institutions and charitable organizations.

Subject to the discretion of Atlantis to accept a lower threshold, the minimum investment for a
separately managed account is generally US$25 million.

Methods of Analysis, Investment Strategies, and Risk of Loss

       Methods of Analysis and Investment Strategies

Atlantis provides investment advice primarily on the equity securities of companies earning the
predominant portion of their income or holding the predominant part of their assets in Asia. In
general, Atlantis invests Client assets in the stock of publicly-traded companies, though it or its
affiliates also offer investment advice in relation to private equity investments and a variety of
investment instruments.

Subject to the investment guidelines and restrictions, Clients may invest, directly or indirectly, in
a wide variety of investments and instruments including, without limitation, equities, equity-
related instruments, as well as convertible securities, asset-backed securities, securities issued by
public and private issuers, futures, commodities, and currencies. Clients may also invest in
derivative instruments, such as swaps, repurchase and reverse repurchase agreements, forward
contracts, credit default swaps, collateralized debt obligations, and contracts for differences, for
speculative, market access or hedging purposes in accordance with their respective investment
objectives.

Atlantis relies on proprietary research as the primary basis of its investment decision-making.
Typically, investment research professionals visit issuers whose securities represent potential
investments and meet with management to assess company quality and suitability for investing.
Atlantis will generally look to target undervalued growth companies and focuses on companies
that exhibit some or all of the following characteristics:

      Attractive valuation multiples;
      Sustainable dividend payout;
      Stable return on equity with above market average earnings per share growth;
      Strong brand, product, or service and market niche;
      Significant market share or a market leader;
      Companies with management ownership; and
      Solid balance sheets and free cash flow.

       Risk of Loss

Investing in securities involves the risk of loss that Clients and investors should be prepared to
bear. An investment with Atlantis should only be made after consultation with independent
qualified sources of investment and tax advice. No guarantee or representation is made that any
Atlantis investment program will be successful and performance could be negatively impacted by
a number of risks, including, but not limited to:

Investment Diversification – Atlantis may invest a significant proportion of Client assets in the
securities of a single company, sector, country or region, which may increase the risk of loss.

Liquidity – The Asian markets in which Atlantis invests on behalf of its Clients may have a
relatively low volume of trading. Securities of companies in such markets may also be less liquid
and more volatile than securities of comparable companies elsewhere.

Small Company Risk - Certain Atlantis investment programs focus on the securities of small to
mid-sized issuers. Securities of smaller companies are often less liquid than those of large
companies and this could make it difficult to sell a small company security at a desired time or
price. As a result, small company securities may fluctuate relatively more in price.

Counterparty (Credit) Risk – Clients may enter into transactions in OTC markets whereby they
will be exposed to the risk that the counterparty may default on its obligations to perform under
the relevant contract. In the event of a bankruptcy or insolvency of counterparty, Clients could
experience delays in liquidating a position and may incur significant losses. (See also “Market
Access Products”, below).

Valuation risk – is the risk of not valuing transactions and positions appropriately. Atlantis will
seek to ensure that Clients’ assets are priced accurately, reflecting the prices at which they could
likely be traded in an orderly fashion in the open market. This is done in accordance with
Atlantis’s Valuation Policies and Procedures.

Investments in The People’s Republic of China – Atlantis makes significant investments on behalf
of Clients in Chinese securities. The overall economic conditions in mainland China (i.e. the
“PRC”) may have a substantial impact on portfolio performance. Economic developments in
China follow patterns different from those in other countries as a result of differences in various
economic aspects, including economic structure, living standard, growth rate, level of
government intervention in the economy, allocation of resources, and rate of inflation.

The interpretation or application of current laws or regulations in China may also have adverse
effects on investments. The value of Clients’ assets may be affected by political and regulatory
uncertainties, such as international and Chinese political developments and changes in
governmental policies in areas including taxation, foreign investment, capital repatriation,
currency fluctuation, and foreign exchange control. In addition, there is a greater degree of
governmental involvement in and control over the economy in mainland China than in more
developed markets. The Chinese government exerts considerable influence on the development
of the Chinese stock market. From time to time, official measures may be taken that affect listed
companies and their market prices in China and overseas.

Market Access Products – Atlantis may, where authorized by the relevant Client, use “market
...
Type Form D Funds Date Sold AUM
HF Riverwood Fortune Fund 2012-06-01 31.5 M
Other Atlantis China Fund 2012-03-29 36.8 M
HF Atlantis China Healthcare Fund 2012-03-29 27.4 M
Other Atlantis New China Fortune Fund 2012-03-29 19.3 M
AUM Breakdown Accounts AUM ($B)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 0 0.0
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 0 0.0
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 13 0.5
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 0 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 0 0.0
(n) Other 0 0.0
Total 15 0.5
By Discretionary
Discretionary 15 0.5
Non-Discretionary 0 0.0
Total 15 0.5
By Non-United States Persons
Non-United States Persons 0.5
United States Persons 0.0
Total 15 0.5
Firm Profile (Form ADV)
Discretionary AUM$1.2B
Clients15 (100 non-US)
ServesInstitutional
Fund TypesHedge Fund
LEI25490004B8LKDPE9SE12
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