Nilzon Capital Inc. Firm Brochure v1.3

Firm Brochure
Nilzon Capital Inc.

SEC Number: 802-120166
FINRA CRD Number: 311722
Exempt Reporting Adviser
United States of America Republic of Indonesia

Registered Agent Palma One Building Suite 308
16192 Coastal Highway Jl. H.R. Rasuna Said Kav. X2 No. 4
Lewes, Delaware 19958 Jakarta Selatan, Indonesia 12950
www.nilzoncapital.com
This document is not intended to offer or to promote the offer or sale of the securities or promote
service in the United States or to US persons as defined in Regulation S under the US Securities Act of
1933.
December 31, 2020
This Brochure provides information about the qualifications and business practices of Nilzon Capital Inc. (“Nilzon Capital”).
If you have any questions about the contents of this Brochure, please contact us at +62-851-5535-1231 or through
www.nilzoncapital.com. The information in this Brochure has not been approved or verified by the United States Securities
and Exchange Commission (“SEC”) or by any state securities authority. Nilzon Capital Inc. is an exempt reporting adviser with
the SEC. Registration of an investment adviser does not imply a certain level of skill or training.
Additional information about Nilzon Capital Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov.
Nilzon Capital Inc. Firm Brochure
ITEM 2 MATERIAL CHANGES

• Addition of non-US persons disclaimer in the cover page.
• Addition of Automatic Billing disclosure in page 6 and page 7.
There may be a newer version of this brochure available for reference. Please contact us to request
the latest version of this brochure.
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ITEM 3 TABLE OF CONTENTS
ITEM 2 MATERIAL CHANGES .............................................................................................................. 1

ITEM 3 TABLE OF CONTENTS ............................................................................................................. 2
ITEM 4 ADVISORY BUSINESS .............................................................................................................. 3
ITEM 5 FEES AND COMPENSATION.................................................................................................... 6
ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .......................................... 7
ITEM 7 TYPES OF CLIENTS .................................................................................................................. 8
ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................... 8
ITEM 9 DISCIPLINARY INFORMATION .............................................................................................. 10
ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........................................... 11
ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND
PERSONAL TRADING ........................................................................................................................ 11
ITEM 12 BROKERAGE PRACTICES ..................................................................................................... 12
ITEM 13 REVIEW OF ACCOUNTS ...................................................................................................... 13
ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION ............................................................. 14
ITEM 15 CUSTODY ............................................................................................................................ 14
ITEM 16 INVESTMENT DISCRETION ................................................................................................. 14
ITEM 17 VOTING CLIENT SECURITIES ............................................................................................... 15
ITEM 18 FINANCIAL INFORMATION ................................................................................................. 15
ADDITIONAL INFORMATION ............................................................................................................ 16
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ITEM 4 ADVISORY BUSINESS

Description of the Advisory Firm
Nilzon Capital Inc. (“Nilzon Capital”) is an investment advisory firm currently exempt reporting with
the United States Securities and Exchange Commission (“SEC”). Nilzon Capital provides comprehensive
financial advisory services to help investors to better allocate their assets through exchange-traded
securities available in the global markets.
Nilzon Capital is a Delaware general corporation established in October 2020.
Frizon A. Putra is the founder of Nilzon Capital Inc. Mr. Putra has over 8 years of experience in investing
and capital market. Mr. Putra founded Nilzon Capital after spending the previous 6 years at PT RHB
Sekuritas Indonesia, a subsidiary of Malaysian RHB Investment Bank Bhd. vested with USD35 million
net-adjusted working capital, where he served as Assistant Vice President of Corporate and
Investment Banking Services Division. During his career, Mr. Putra is enthusiastic of international IPOs,
cross-border transaction, and capital fundraising both in the developing and developed markets. Mr.
Putra is actively tracking the development of new industries, such as self-driving cars, battery, clean
energy, and consumer mobility.
John Octavianus, Nilzon Capital’s Chief Executive Officer and Chairman, is the principal advisor of the
company. Mr. Octavianus has over 11 years in investing and capital market. Mr. Octavianus previously
served as Head of Investment Banking at PT UOB Kay Hian Sekuritas (a subsidiary of United Overseas
Bank), Vice President at PT RHB Sekuritas Indonesia (a subsidiary of RHB Investment Bank Bhd.), and
Senior Manager at PT Maybank Kim Eng Sekuritas (a subsidiary of Maybank). Mr. Octavianus is highly
experienced in international IPOs, capital fundraising, and corporate restructuring from various
industries. Mr. Octavianus is actively tracking various sectors for the benefits of his investors and
clients, such as ICT, electric vehicles, consumers, and fintech.
Nilzon Capital’s goal is to help its customers to invest in a balanced portfolio consisting of high-flyer
disruptors and high-yielding established business. By using an active re-allocation strategy and sector-
agnostic portfolio focus, Nilzon Capital believes its customers can withstand long term business cycles
while producing aggressive capital appreciation.
Types of Advisory Services
• Advisory Services to Separately Managed Accounts, Pooled Investment Vehicles and Other Clients
Nilzon Capital provides investment advisory services to certain non-US persons separately
managed accounts and pooled investment vehicles (corporation, limited liability company,
private/public funds, foundations, endowments, high net worth clients, individual, other
investment advisor and their customers and clients, and financial institutions and their customers
and clients). Such accounts will be managed in accordance with investment objectives, strategies,
policies and restrictions established by each client and documented in a written advisory
agreement with, or on behalf of, each client and Nilzon Capital.
Based on its discretion, there are 2 (two) types of separately managed accounts that Nilzon Capital
serves: (i) Discretionary, with no minimum investment amount; and (ii) Non-Discretionary, with
minimum investment of at least $3,500.
Nilzon Capital will request discretionary authority from clients to gain blanket approval to select
portfolio allocation and execute transaction along the Discretionary contractual agreement.
Depending upon the contractual arrangements, Nilzon Capital executes purchases and sales of
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securities for these accounts through broker-dealer firms Nilzon Capital selects including firms
that can furnish Nilzon Capital with investment research and other brokerage services. Certain
clients can choose to execute their own portfolio transactions based on advice and/or information
provided by Nilzon Capital.
• Research Services
As a part of proper due diligence prior investing in particular securities, Nilzon Capital can engage
into discussion with clients, potential clients or other third parties, one or more issuers (public or
private) that it does not then hold in any portfolio managed by Nilzon Capital and which Nilzon
Capital could consider for investment. Any such formal discussions are solely for informational
purposes and will only regard publicly available information. Such discussions could include,
among other things, the views of Nilzon Capital’s management regarding the issuer or its
securities, the issuer’s financial condition or prospects, or the merits generally of an investment
(or non-investment) in that issuer or any industry or sector of which that issuer is a part. Nilzon
Capital is under no obligation to enter into such discussions with any client or all clients and can
elect to have such discussions only with certain clients or with third parties in its sole discretion.
Nilzon Capital will not, as a result of any such discussion, be limited in any way from purchasing or
selling investments of any such issuer, including investments that could be or appear to be
inconsistent with the views expressed in such discussion.
• Research Publications and Client Services
Nilzon Capital may publishes its research analysis on its internal/external website in an on-going
effort to educate investors and as a part of its marketing efforts. This publication includes blog
articles, videos, or other content formats, hosting of educational research events, and sending of
research newsletters and market commentaries to clients and subscribers.
Client-Tailored Services and Client-Imposed Restrictions
Generally, Nilzon Capital provides advisory services to each client under the terms of an Advisory
Agreement between Nilzon Capital and the client or on behalf of the client. As a general matter, Nilzon
Capital’s management of any pooled investment vehicle or registered or unregistered fund will be in
accordance with the governing documents for that vehicle or fund including the investment objective,
guidelines, differentiated investment strategy or strategies, policies and restrictions for the vehicle or
fund. Nilzon Capital’s management of such vehicle or fund is not intended to reflect the specific
requirements or needs of any individual investor in the vehicle or fund.
Nilzon Capital’s management of a client’s separately managed account will be consistent with the
particular investment objective, guidelines, differentiated investment strategy or strategies, policies
and restrictions the client selects for that account.
Within a given investment theme and consistent with the account or fund’s stated investment
objectives, investment strategies, guidelines, policies and restrictions, Nilzon Capital typically has the
authority to select which and how many securities and other instruments to buy or sell without
consultation with the client (or, in the case of a fund, the management of or investors in the fund).
In certain circumstances, Nilzon Capital will agree to manage a client’s account subject to certain
reasonable restrictions imposed by the client, including, without limitation, the exclusion of specific
securities or types of securities, within that account, cash levels permitted in the account or
techniques that can be used in managing the account. However, Nilzon Capital reserves the right not
to enter into an agreement with a prospective client, or to terminate an Advisory Agreement with an
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existing client, if any proposed limitation or restriction is, in Nilzon Capital’s opinion, likely to impair
Nilzon Capital’s ability to appropriately provide services to a client or Nilzon Capital otherwise believes
the limitations or restrictions to be operationally impractical or unfeasible.
Nilzon Capital does not allow its client to buy securities on margin or using borrowings available in the
capital market or brokerage account. The portfolio composition of accounts within the same
investment theme can differ at any given time. These differences in portfolio composition are
attributable to a variety of factors, including, but not limited to, the type of account (e.g., manner of
trade execution), client objectives, guidelines, policies, practices (e.g., securities lending,) limitations
and restrictions, size of the account, date of initial funding, whether Nilzon Capital has investment
discretion, and significant account activity (e.g., significant number of contributions and/or
withdrawals). As a result, the performance of an account within a particular investment theme could
differ from other accounts having the same investment strategy.
Discretionary Assets Under Advisory
As of 31 December 2020, Nilzon Capital’s assets under advisory breaks out as follows:
• Discretionary : $128,370
• Non-Discretionary : $0
Wrap Fee Program
A wrap fee program is an investment program where the investor pays one stated fee that includes
management fees, transaction costs, fund expenses, and other administrative fees. Nilzon Capital
does not participate in any wrap fee programs.
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ITEM 5 FEES AND COMPENSATION

Advisory Fee
Total Assets Under Advisory Annualized Fee

$20,001 and more 1.50%
$5,001 - $20,000 1.75%
$2,001 - $5,000 2.00%
$2,000 and less 2.50%
Nilzon Capital’s fee rates do not include fees that separately managed account clients normally pay to
other third-party service providers, including custodial, administrative, securities lending agent,
consultant, brokerage, and exchange fees.
Advisory Fee is calculated as a blended annualized percentage, applied on a daily basis and charged
monthly. The total blended rate is the sum of the fee amount for each range up to the client's current
NAV.
The fees charged to separately managed accounts that are having substantial NAV are negotiable and
typically will vary and can be reduced or can include breakpoints depending on a number of factors
including, but not limited to: the type of client, the size of the account, the total amount of client AUM
managed or advised by Nilzon Capital, whether the client wishes to impose particular limitations or
restrictions on Nilzon Capital’s discretionary investment authority (e.g., restrictions on the types of
securities that Nilzon Capital acquires for the account), and other business considerations. Nilzon
Capital generally imposes investment minimums on separately managed accounts.
Advisory Fee Calculation Example:
Client A is having a portfolio Z worth $25,000 flat for the whole year 20XX. Thus, Client A Advisory Fee
breakdown is as follows:
• First Range : 2.50% of $2,000 = $50.00

• Second Range : 2.00% of $3,000 ($5,000 less $2,000) = $60.00
• Third Range : 1.75% of $15,000 ($20,000 less $5,000) = $262.50
• Fourth Range : 1.50% of $5,000 ($25,000 less $20,000) = $75.00
Client A total Advisory Fee for the year of 20XX is $447.50.
Allocation Fee
All of Nilzon Capital clients are subject to $0.51 allocation fee per securities instrument traded, paid
in excess of standard brokerage fee paid to the broker-dealer and negotiable to clients with substantial
NAV. Broker-dealer may impose a minimum standard brokerage fee of $10 monthly for certain
account.
Automatic Billing
Nilzon Capital may request custodial, administrative, and/or broker-dealer service provider(s) to
collect Advisory Fee using an automated billing system that periodically charges and deduct fees
payable to Nilzon Capital from client’s cash account. Partial or complete liquidation will be forced in
the event that the charged Advisory Fee leads to a margin loan for cash account or exceeding excess
liquidity for margin account.
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ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT

A performance fee arrangement is a method of compensating an investment adviser based on a share
of the gains or appreciation of the client’s assets under advisory.
Nilzon Capital’s qualified clients per SEC Rule 205-3 and non-US clients are subject to the following
Performance Fee:
Performance Fee : 20% of Quarterly P&L

Benchmark : S&P 500 Stock Index Performance
Billing Period : 31 March, 30 June, 30 September, and 31 December
Look Back Quarters :2
Prorate Withdrawals : Yes
Nilzon Capital spirit is to put clients’ interest first and aspire to grow together with them. Thus, Nilzon
Capital only charges Performance Fee on excess of the S&P 500 Stock Index performance as
benchmark. Nilzon Capital does not charge Performance Fee if particular client(s) portfolio is fall short
or make less than what S&P 500 Stock Index make during the same quarter.
Look Back Quarter means that Nilzon Capital keeps track of cumulative losses per billing period within
specified look-back period. A loss in any period will be added to the look-back period’s cumulative
losses. A gain in any period will decrease the cumulative loss recorded to date.
Prorate Withdrawal means that withdrawals in the current period reduce any cumulative losses that
are carried over from previous periods. The losses are reduced in proportion to the percentage of
equity that was withdrawn. Nilzon Capital neither compensate client’s capital loss nor pay for client’s
negative return.
Performance Fee Calculation Example:
Client A is having a portfolio Z worth $25,000 at the start of the first quarter of year 20XX. As of 31
March 20XX, Client A portfolio is indicating a 10% gain (or worth $2,500) while S&P 500 Stock Index is
indicating a 7% gain (comparable to a $1,750 gain relative to Client A portfolio). Thus, Client A
Performance Fee breakdown is as follows:
Performance Fee = (Portfolio Return - Benchmark Return) x Performance Fee

= ($2,500 - $1,750) x 20%
= $750 x 20%
= $150
Client A total Performance Fee for the first quarter of year 20XX is $150.00.
Automatic Billing
Nilzon Capital may request custodial, administrative, and/or broker-dealer service provider(s) to
collect Performance Fee using an automated billing system that periodically charges and deduct fees
payable to Nilzon Capital from client’s cash account. Partial or complete liquidation will be forced in
the event that the charged Advisory Fee leads to a margin loan for cash account or exceeding excess
liquidity for margin account.
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ITEM 7 TYPES OF CLIENTS

Currently, Nilzon Capital provides investment advisory services to certain separately managed
accounts and pooled investment vehicles (corporation, limited liability company, private/public funds,
foundations, endowments, high net worth clients, individual, other investment advisor and their
customers and clients, and financial institutions and their customers and clients). Nilzon Capital
typically require no minimum account size, but reserve the full discretion to ask all or particular
client(s) to meet certain minimum account size.
ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS

Methods of Analysis and Investment Strategies
Nilzon Capital’s main investment focus is long-term growth of capital by engaging long-only positions.
The investment strategy is based on a fundamental valuation and a combination of momentum
approach and comparable valuation approach. Momentum approach is an approach to selectively
buying or selling securities based on a short-term event or price action that is having less relevance to
the whole valuation in the long run. Meanwhile, comparable valuation approach is an approach to
selectively buying or selling securities based on attractiveness of certain securities compared to the
currently available peers in the same industry with the same business and outlook.
Since Nilzon Capital’s main focus is to enable clients to expect better return than S&P 500 Stock Index,
the whole portfolio may be constructed or re-constructed based on how certain modification to the
S&P 500 Stock Index constituents may improve risk-reward relation. Such modification, although
properly mitigated, may also expose client’s portfolio to a greater adverse risk that leads to capital
loss or underperformance.
Description of Material Risks
The following paragraphs list some material risks that investor may be exposed to and may be resulting
in a substantial capital loss. Other material risks that are not listed here may also emerge as a results
of market dynamics and company-specific events. Investor is advised to read all risks carefully and
seek additional third-party guidance if needed. Nilzon Capital is not responsible and bear no liability
to the client/investor for any loss(es) and deficit(s).
Market Risk. The value of the assets will fluctuate as the markets in which the client invests fluctuate.
The value of the client’s investments may decline, sometimes rapidly and unpredictably, simply
because of economic changes or other events, including inflation (or expectations for inflation),
interest rates, global demand for particular products or resources, natural disasters or events,
exchange trading suspensions and closures, infectious disease outbreaks or pandemics, terrorism,
regulatory events and government controls, that affect large portions of the market.
Index-Tracking Risk. The returns of the index-based investment accounts may not match the return of
the applicable index for a number of reasons. For example, the accounts will incur a number of
operating expenses not applicable to the index and will incur costs associated with buying and selling
securities, especially when rebalancing the securities holdings of the investment accounts to reflect
changes in the composition of the relevant index. The accounts also bear the costs and risks associated
with buying and selling securities while such costs and risks are not factored into the return of the
relevant index. In addition, the accounts may not be able to invest in certain securities included in the
index or may not be able to invest in them in the exact proportions in which they are represented in
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the index, due to legal restrictions or limitations imposed by the governments of certain countries,
potential adverse tax consequences or other regulatory reasons.
Market Trading Risk. Market trading risks include losses from trading in secondary markets, the
existence of extreme market volatility or potential lack of an active trading market.
Security Selection Risk. The value of an individual security and, similarly, the value of an investment in
that security, may rise or fall. Nilzon Capital’s investment process for a particular strategy may favor
specific securities, industries or sectors that underperform investments in other securities, industries,
sectors, or the market generally.
Portfolio Turnover Risk. Each investment account that is based on the performance of an index is
adjusted to add or delete companies from such accounts upon certain events or corporate actions
affecting companies that are included in the relevant index. As companies leave and enter the relevant
index, accounts based on the index will be adjusted to match the current composition of the relevant
index. This process may result in the realization of capital gains or losses. Because such accounts will
buy and sell securities as needed to maintain their correlation to the relevant index, portfolio turnover
in such accounts may be substantial.
Equity Securities Risk. The value of equity securities may fall due to general market and economic
conditions, perceptions regarding the industries in which the issuers of securities participate or factors
relating to specific companies. An unfavorable earnings report or a failure to make anticipated
dividend payments by an issuer may affect the value of the issuer’s equity securities. Equity securities
may also be particularly sensitive to general movements in the stock market, and a decline in the
broader market may affect the value of equity investments.
Issuer Risk. The value of an issuer’s equity securities may decline for reasons directly related to the
issuer, such as management performance, financial leverage and reduced demand for the issuer’s
goods or services. The value of an individual security or particular type of security can be more volatile
than the market as a whole and can perform differently from the value of the market as a whole. The
value of securities of smaller issuers can be more volatile than that of larger issuers. A change in the
financial condition, market perception or credit rating of an issuer of securities may cause the value
of its securities to decline.
Management Risk. Nilzon Capital applies investment strategies, techniques and analyses in making
investment decisions, but there can be no guarantee that these actions will produce the intended
results. The ability of Nilzon Capital to successfully implement the investment strategy will significantly
influence the performance of an account.
Large-Capitalization Companies Risk. Large-capitalization companies tend to be less volatile than

companies with smaller market capitalizations. In exchange for this potentially lower risk, the value of
a large-capitalization company may not rise as much as that of a company with a smaller market
capitalization.
Small- and Medium-Capitalization Companies Risk. Small- and medium-capitalization companies may
be more volatile and more likely than large-capitalization companies to have narrower product lines,
fewer financial resources, less management depth and experience and less competitive strength.
Returns on investments in securities of small- and medium-capitalization companies could trail the
returns on investments in securities of large-capitalization companies.
Micro-Capitalization Companies Risk. Micro-capitalization companies are subject to substantially

greater risks of loss and price fluctuations because their earnings and revenues tend to be less
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predictable (and some companies may be experiencing significant losses). Their share prices tend to
be more volatile and their markets less liquid than companies with larger market capitalizations. The
shares of micro-capitalization companies tend to trade less frequently than those of larger, more
established companies, which can adversely affect the pricing of these securities and the future ability
to sell these securities.
Liquidity Risk. Certain assets may be difficult (or impossible) to sell at a desired time and at a desired
price. As a result, Nilzon Capital may need to hold certain assets longer that it would like and may
forego other investment opportunities. Liquidity risk can be more pronounced during periods of
market turmoil.
Regulation Risk. Laws and regulations affecting Nilzon Capital’s business change from time to time.
Nilzon Capital cannot predict the effects, if any, of future legal and regulatory changes on Nilzon
Capital’s business or the services Nilzon Capital provides.
Technology and Cyber Security Risks. Investment advisers, including Nilzon Capital, must rely in part
on digital and network technologies to conduct their businesses and to maintain substantial
computerized data relating to client account activities. These technologies include those owned or
managed by Nilzon Capital as well as those owned or managed by others, such as custodians, financial
intermediaries, transfer agents, and other parties to which Nilzon Capital or such other parties
outsource the provision of services or business operations.
Nilzon Capital and such third parties and the systems Nilzon Capital uses could be subject to a variety
of possible cybersecurity incidents or similar events that could potentially result in the inadvertent
disclosure of confidential computerized data or client data to unintended parties, or the intentional
misappropriation or destruction of data by malicious hackers mounting an attack on computer
systems.
Despite reasonable precautions, cybersecurity incidents could occur, and might in some circumstances
result in unauthorized access to sensitive information about Nilzon Capital or its clients. In addition,
such incidents might cause damage to client accounts, data, systems or affect client services.
Furthermore, these systems may fail to operate properly or become disabled as a result of events or
circumstances wholly or partly beyond Nilzon Capital’s or others’ control. Technology failures,
whether deliberate or not, including those arising from use of third-party service providers or client
usage of systems to access accounts, could have a material adverse effect on Nilzon Capital’s business
or Nilzon Capital’s clients and could result in, among other things, financial loss, reputational damage,
regulatory penalties or the inability to transact business.
ITEM 9 DISCIPLINARY INFORMATION

Neither Nilzon Capital, nor any of its management persons, have been the subject of any material
legal or disciplinary action.
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ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS

Registration as a Broker/Dealer or Broker/Dealer Representative
Neither Nilzon Capital nor its representatives are registered as, or have pending applications to
become, a broker/dealer or a representative of a broker/dealer in the United States of America.
However, Nilzon Capital Founder and Chief Executive Officer & Chairman are holding professional
licenses issued by the Otoritas Jasa Keuangan (Financial Service Authority of Republic of Indonesia) as
a part of their professional licenses to operate in Indonesia, respectively:
Frizon A. Putra (Founder):

• Investment Manager Representative License No. KEP-210/PM.211/WMI/2016, extended with
No. KEP-655/PM.211/PJ-WMI/2018;
• Broker-Dealer Representative License No. KEP-397/PM.212/WPPE/2016, extended with No.
KEP-39/PM.212/PJ-WPPE/2020; and
• Underwriter Representative License No. KEP-18/PM.212/WPEE/2017, extended with No. KEP-
103/PM.212/PJ-WPEE/2020.
John Octavianus (Chief Executive Officer, Chairman):

• Underwriter Representative License No. KEP-45/BL/WPEE/2011, extended with No. KEP-
382/PM.212/PJ-WPEE/2018.
Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity

Trading Advisor
Neither Nilzon Capital nor its representatives are registered as or have pending applications to become
either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or
an associated person of the foregoing entities.
Material Relationships to this Advisory Business and Possible Conflicts of Interests
Neither Nilzon Capital nor its representatives have any material relationships to this advisory business
that would present a possible conflict of interest.
Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections
Nilzon Capital does not utilize nor select third-party investment advisers. All assets are advised by
Nilzon Capital.
ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND

PERSONAL TRADING
Code of Ethics and Personal Trading
Nilzon Capital has adopted Code of Ethics that establishes personal trading guidelines and restrictions
applicable to Nilzon Capital employees and Nilzon Capital employee’s family members (“Access
Persons”). These guidelines and restrictions must be followed for all transactions in all accounts in
which an Access Persons have a beneficial interest. Access Persons must submit required quarterly
reports of securities transactions (or furnish brokerage statements).
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Recommendations Involving Material Financial Interests
Nilzon Capital does not recommend that clients buy or sell any security in which a related person to
Nilzon Capital or Nilzon Capital has a material financial interest.
Investing Personal Money in the Same Securities as Clients
From time to time, representatives of Nilzon Capital may buy or sell securities for themselves that
they also recommend to clients. This may provide an opportunity for representatives of Nilzon Capital
to buy or sell the same securities before or after recommending the same securities to clients resulting
in representatives profiting off the recommendations they provide to clients. Such transactions may
create a conflict of interest. Nilzon Capital will keep record of Access Person’s quarterly holding that
could be construed as conflicts of interest and will never engage in trading that operates to the client’s
disadvantage when similar securities are being bought or sold.
Trading Securities at/around the Same Time as Clients
Subject to Nilzon Capital’s Code of Ethics, Nilzon Capital employees can engage in a transaction in a
security at or around the same time as Nilzon Capital buys or sells that same security for its client
portfolios. Generally, clearance for an employee transaction typically will not be granted: (i) if the
security is included in a client’s portfolio, on a day when the security is being considered for purchase
or sale by the client; (ii) if the security is not included in a client’s portfolio but notice has been given
that such security will be added to a client’s portfolio, until such time as Nilzon Capital completes such
transactions for the applicable client’s portfolio; or (iii) when the security is being considered by Nilzon
Capital for purchase or sale for a client. The CCO also reserves the right to revoke clearance any time
after it is granted and before the transaction is executed and/or deny clearance of any personal
securities transaction. The CCO, based on his/her consideration, can enable company-wide
requirement for Access Person to have their investment managed and supervised by Nilzon Capital, in
the same investment theme or product/services that Nilzon Capital make available to its clients.
ITEM 12 BROKERAGE PRACTICES

Selection of Broker-Dealers to Execute Transactions in Client Accounts
Nilzon Capital reserve the authority to determine which broker-dealer will execute transactions. In
exercising investment discretion over client accounts, or in responding to specific client instructions,
Nilzon Capital normally places orders with broker-dealers to execute transactions for the accounts.
Some clients that designate Nilzon Capital as the investment manager and/or adviser for their account
nonetheless have the ability to place their own trades for their account. Where a client chooses to
execute a trade, Nilzon Capital is not responsible for the execution or the selection of broker-dealers
for such trades.
When clients grant brokerage discretion to Nilzon Capital, Nilzon Capital’s general policy is to use its
best efforts to seek to obtain best execution for all client portfolio transactions, taking into account a
variety of factors such as:
• the security price;

• the commission rate;
• the reliability, integrity, creditworthiness and financial condition of the broker-dealer;
Page 12
• the general execution, clearance, settlement, responsiveness, and operational capabilities of

the broker-dealer;
• the research capabilities of the broker-dealer (e.g., soft-dollar arrangements); and
• the number of trading errors committed by the broker-dealer.
It is not Nilzon Capital’s policy to seek the lowest available commission rate where it believes that a
broker or dealer charging a higher commission rate would offer better overall execution, including for
example greater reliability or better price or execution. While Nilzon Capital seeks best execution for
discretionary transactions, Nilzon Capital cannot assure that best execution will be achieved for each
client transaction.
Nilzon Capital pays, or be deemed to pay, commission rates higher than it might otherwise pay to
receive research or brokerage services that Nilzon Capital views as beneficial to client accounts.
Research or brokerage services Nilzon Capital receives for conducting transactions in a client account
can benefit other accounts and it is possible that a particular account will not benefit from services
obtained because of transactions conducted through that account. Nilzon Capital will not attempt to
track or allocate the benefits of research or brokerage services it receives to the commissions
associated with a particular account or group of accounts. Additionally, certain clients could bear more
of the cost of soft dollar arrangements than other clients.
Aggregating (Block) Trading for Multiple Client Accounts
Where Nilzon Capital has discretion, Nilzon Capital can determine that the purchase or sale of a
particular security is appropriate for more than one client account and can aggregate client orders
into one order (“Block Orders”) for execution purposes. Block trading can avoid the adverse effect on
a security’s price when simultaneous separate and competing orders are placed. When aggregating
orders and subsequently allocating Block Orders (purchases and sales) to individual client accounts, it
is Nilzon Capital’s policy to treat all clients fairly and to achieve an equitable distribution of aggregated
orders.
Some types of purchase or sale transactions cannot be included in Block Orders. For instance, trades
resulting from the opening and closing of accounts, or from contributions to or withdrawals from
existing accounts, often must be executed on an individual basis rather than aggregated with other
trades. In such cases, clients might not receive as favorable executions as they might otherwise receive
from Block Orders.
ITEM 13 REVIEW OF ACCOUNTS

Frequency and Nature of Periodic Account Reviews
The Nilzon Capital Team will monitor each client account and fund on a regular basis to seek to ensure
portfolio level compliance (adherence to investment strategy and client guidelines) and to determine
whether to take any action for that account based on its investment objective, strategy or strategies,
guidelines, policies, and restrictions and, more generally, based on Nilzon Capital’s review of economic
and market conditions. For separately managed accounts, Nilzon Capital will review each such account
as agreed to with the client.
Page 13
Factors that Will Trigger a Non-Periodic Review of Separately Managed Accounts
Factors that will dictate the timing and nature of separately managed account reviews will include the
following: contributions or withdrawals of cash from an account; a determination to change an
account’s cash level; a client's direction to refrain from purchasing a particular security or class of
securities for such client’s account; a client's request for information regarding the performance or
structure of an account; changes in the investment objectives, strategy or strategies, guidelines,
investment policies or investment restrictions; account performance; and requirements imposed by
court order or regulatory decree (SEC, Department of Labor, etc.).
Content and Frequency of Regular Reports
For each separately managed account, Nilzon Capital will provide, either directly or through a
designated third party, all information it has agreed to provide to each such client and other persons
or entities that they designate. Typically, client will receive a monthly report detailing assets held,
asset value, asset performance, calculation of fees, and other relevant information.
ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION

Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards
or Other Prizes)
Nilzon Capital does not receive any economic benefit, directly or indirectly from any third party for
advice rendered to Nilzon Capital’s clients.
Compensation to Non-Advisory Personnel for Client Referrals
Nilzon Capital may directly or indirectly compensate any person who is not advisory personnel for
client referrals.
ITEM 15 CUSTODY
Nilzon Capital does not act as custodian on client’s assets, despite being the Advisor and granted
discretionary access by the client. When advisory fees are deducted directly from client accounts by
third-party custodian, Nilzon Capital will still be unqualified as custodian of client's assets. Clients will
receive all account statements and billing notices that are required in each jurisdiction, and they
should carefully review those statements for accuracy. Nilzon Capital does not provide account
statements to clients in addition to those provided by the custodian.
ITEM 16 INVESTMENT DISCRETION

Nilzon Capital accepts discretionary investment advisory services to eligible clients. The Investment
Advisory Contract established with each client sets forth the discretionary authority for trading. Before
accepting discretionary authority, Nilzon Capital enters into a written Advisory Agreement with a
client or on behalf of a client. In the case of a client with a separately managed account, this Advisory
Agreement can include investment guidelines or similar documents describing the client’s investment
objective, strategy or strategies, policies, limitations, and restrictions on Nilzon Capital’s management
of the account, and a benchmark.
Page 14
Nilzon Capital reserves the right not to enter into an Advisory Agreement with a prospective client, or
to terminate an Advisory Agreement with an existing client, if any proposed limitation or restriction
is, in Nilzon Capital’s opinion, likely to impair Nilzon Capital’s ability to appropriately provide services
to a client or Nilzon Capital otherwise believes the limitations or restrictions to be operationally
impractical or unfeasible. Certain investment restrictions can limit Nilzon Capital’s ability to execute
the investment strategy and reduce the account’s performance as a result.
Nilzon Capital will exercise discretionary authority with respect to the management of Pooled
Investment Vehicles, Sub-Advised Funds and Other Registered Investment Companies in accordance
with the objective(s), strategies, guidelines, practices, policies, limitations, restrictions, and
benchmarks set forth the prospectus (and Statement of Additional Information if applicable) or
offering document and/or disclosure document for each vehicle, fund or investment company.
ITEM 17 VOTING CLIENT SECURITIES

Nilzon Capital will not ask for, nor accept voting authority for client securities. Clients will receive
proxies directly from the issuer of the security or the custodian. Clients should direct all proxy
questions to the issuer of the security.
ITEM 18 FINANCIAL INFORMATION

Balance Sheet
Nilzon Capital neither requires nor solicits prepayment of more than $500 in fees per client, six months
or more in advance, and therefore is not required to include a balance sheet with this brochure.
Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to

Clients
Neither Nilzon Capital nor its management has any financial condition that is likely to reasonably
impair Nilzon Capital’s ability to meet contractual commitments to clients.
Bankruptcy Petition
Nilzon Capital has not been the subject of a bankruptcy petition in the last ten years.
Page 15
ADDITIONAL INFORMATION
Privacy Policy
Nilzon Capital is committed to protecting the confidentiality of information clients send to us.
Regulation S-P adopted by the SEC requires that Nilzon Capital provide the following information to
you.
Information about you that Nilzon Capital collect: Nilzon Capital can collect non-public personal
information about you and your transactions from the following sources: your account forms, through
Nilzon Capital’s website, through your transactions with us or others, email and social media.
How Nilzon Capital use your information: As permitted by law, Nilzon Capital can share information
about you with non-affiliated third parties that provide services to us or as necessary to service your
account. Otherwise, Nilzon Capital do not disclose your non-public personal information unless
authorized by you in writing or as otherwise permitted by law. This policy applies to non-public
information about current, former or prospective clients who are natural persons.
How Nilzon Capital protect your confidential information: Nilzon Capital has policies that restrict
access to your non-public personal information to employees who need the information to provide
investment services to you. Nilzon Capital maintain physical, electronic and procedural safeguards to
protect your non-public personal information.
Page 16
Brochure Supplement
Nilzon Capital Inc.


1933.
December 31, 2020
FRIZON A. PUTRA
This Brochure Supplement provides information about Frizon A. Putra that supplements the Nilzon Capital Inc. (“Nilzon
Capital”) Brochure. You should have also received a copy of the Brochure. Please contact us at +62-851-5535-1231 or through
www.nilzoncapital.com if you did not receive Nilzon Capital’s Brochure or if you have any questions about the contents of
this supplement.
Nilzon Capital Inc. Brochure Supplement
Name : Frizon A. Putra

Year of Birth : 1993
Item 2‐ Educational Background and Business Experience
Formal education after high school:
Bachelor of Economics in Accounting from Universitas Indonesia
Business background and experience for preceding years:
Nilzon Capital Inc. 2020-present Founder

PT Nilzon Kapital Advisor 2020-present Chief Executive Officer, Director
Made On Earth By Humans LP 2020-present Advisor to Private Equity
PT RHB Sekuritas Indonesia 2015-2021 Assistant Vice President - Investment Banking
Item 3 ‐ Disciplinary Information
None
Item 4 ‐ Other Business Activities
Frizon A. Putra is engaged in other investment-related business or occupations disclosed in his

business background above in Item 2
Item 5 ‐ Additional Compensation
Frizon A. Putra is the founder of Nilzon Capital and may receive earnings from Nilzon Capital. He may
also receive a bonus based on the quality of the advisory services and the overall financial
performance of Nilzon Capital
Item 6 ‐ Supervision
As the Founder of Nilzon Capital, Frizon A. Putra engages on various business-related and non-
investment matters with the Board of Directors
Brochure Supplement
Nilzon Capital Inc.


1933.
December 31, 2020
JOHN OCTAVIANUS
This Brochure Supplement provides information about John Octavianus that supplements the Nilzon Capital Inc. (“Nilzon
Capital”) Brochure. You should have also received a copy of the Brochure. Please contact us at +62-851-5535-1231 or through
www.nilzoncapital.com if you did not receive Nilzon Capital’s Brochure or if you have any questions about the contents of
this supplement.
Nilzon Capital Inc. Brochure Supplement
Name : John Octavianus

Year of Birth : 1984
Item 2‐ Educational Background and Business Experience
Formal education after high school:
Bachelor of Economics in Accounting from Universitas Indonesia
Business background and experience for preceding years:
Nilzon Capital Inc. 2020-present Chief Executive Officer, Chairman

PT Nilzon Kapital Advisor 2020-present Commissioner
Made On Earth By Humans LP 2020-present Advisor to Private Equity
Marvel Investama Inc. 2020-present Chief Executive Officer
PT Marvel Investama Asia 2019-present Chief Executive Officer
PT UOB Kay Hian Sekuritas 2018-2019 Head of Investment Banking
PT RHB Sekuritas Indonesia 2016-2018 Vice President - Investment Banking
PT UOB Kay Hian Sekuritas 2013-2016 Senior Manager
PT Maybank Kim Eng Sekuritas 2012-2013 Senior Manager
PT Indo Premier Sekuritas 2010-2012 Associate
PT Medina Multi Mitra 2009-2010 Consultant
Item 3 ‐ Disciplinary Information
None
Item 4 ‐ Other Business Activities
John Octavianus is engaged in other investment-related business or occupations disclosed in his

business background above in Item 2
Item 5 ‐ Additional Compensation
John Octavianus may receive a salary and may receive earnings from Nilzon Capital. He may also
receive a bonus based on the quality of the advisory services and the overall financial performance of
Nilzon Capital
Item 6 ‐ Supervision
As the CEO and Chairman of Nilzon Capital, John Octavianus engages on daily business and dealing
with various business-related and non-investment matters together with the Board of Directors

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Firm Brochure

Nilzon Capital Inc.

Exempt Reporting Adviser

United States of America Republic of Indonesia

December 31, 2020

ITEM 2 MATERIAL CHANGES

ITEM 3 TABLE OF CONTENTS

ITEM 2 MATERIAL CHANGES .............................................................................................................. 1

ITEM 4 ADVISORY BUSINESS

Nilzon Capital is a Delaware general corporation established in October 2020.

Types of Advisory Services

• Research Publications and Client Services

Client-Tailored Services and Client-Imposed Restrictions

Discretionary Assets Under Advisory

Wrap Fee Program

ITEM 5 FEES AND COMPENSATION

Total Assets Under Advisory Annualized Fee

Advisory Fee Calculation Example:

• First Range : 2.50% of $2,000 = $50.00

Client A total Advisory Fee for the year of 20XX is $447.50.

ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT

Performance Fee : 20% of Quarterly P&L

Performance Fee Calculation Example:

Performance Fee = (Portfolio Return - Benchmark Return) x Performance Fee

ITEM 7 TYPES OF CLIENTS

ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS

Description of Material Risks

Large-Capitalization Companies Risk. Large-capitalization companies tend to be less volatile than

Micro-Capitalization Companies Risk. Micro-capitalization companies are subject to substantially

ITEM 9 DISCIPLINARY INFORMATION

ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS

Frizon A. Putra (Founder):

John Octavianus (Chief Executive Officer, Chairman):

Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity

Material Relationships to this Advisory Business and Possible Conflicts of Interests

ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND

Recommendations Involving Material Financial Interests

Investing Personal Money in the Same Securities as Clients

Trading Securities at/around the Same Time as Clients

ITEM 12 BROKERAGE PRACTICES

• the security price;

• the general execution, clearance, settlement, responsiveness, and operational capabilities of

Aggregating (Block) Trading for Multiple Client Accounts

ITEM 13 REVIEW OF ACCOUNTS

Factors that Will Trigger a Non-Periodic Review of Separately Managed Accounts

Content and Frequency of Regular Reports

ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION

Compensation to Non-Advisory Personnel for Client Referrals

ITEM 16 INVESTMENT DISCRETION

ITEM 17 VOTING CLIENT SECURITIES

ITEM 18 FINANCIAL INFORMATION

Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to

Nilzon Capital Inc.

Exempt Reporting Adviser

United States of America Republic of Indonesia

December 31, 2020

Name : Frizon A. Putra

Item 2‐ Educational Background and Business Experience

Formal education after high school:

Bachelor of Economics in Accounting from Universitas Indonesia

Business background and experience for preceding years:

Nilzon Capital Inc. 2020-present Founder

Item 3 ‐ Disciplinary Information