How We Engage Our Clients and Improve
Our Client Experience

We have developed solid and everlasting relationships as part of our management plan. On all business transactions that occur with clients, partners, or acquisitions, we ensure an efficient communication and relationship. This statement is a core cultural belief and a fundamental element of the success of Oxon PTY Limited. Members of our community tend to share core values that are highly compatible with those that are central to the business and established at the outset — expertise, integrity and discretion. We treat each other with mutual respect, openness and fairness and are driven by a desire to ‘do the right thing’ by all our stakeholders. This is our culture – it is central to our success. We are therefore proactive in building and reinforcing it.

Anti-Bribery And Corruption Framework

Oxon PTY Limited operates within the commercial banking laws and protocols. We make sure all business transactions follow our Code of Conduct and values. As a company, we have enforced a robust framework to prevent all forms of bribery and corruption. Our Anti- Bribery and Corruption Policy forbids the actual or attempted use of any form of bribery or corruption, either directly or indirectly, on Oxon PTY Limited behalf on any business-related activity.

Risk assessment

These include periodic risk assessments to identify and address bribery and corruption risk and controls tailored to manage the risks identified through this process.

Policies & Procedures

Bribery and corruption risks are addressed through a number of other Oxon PTY Limited policies and procedures, including our Anti-Money Laundering and Counter-Terrorism Financing Policy, incorporating Client Identification. This document is a summary of Oxon PTY Limited' Anti-Bribery and Corruption Policy and framework. It is not intended to create third party rights or duties or to form part of any contractual agreement between Oxon PTY Limited and any other party.

Procedures

Oxon PTY Limited staff must take reasonable steps to avoid, giving or accepting gifts and entertainment that are intended to, or may, improperly influence them or others. We also maintains a Whistle-blower Policy and framework which promotes the escalation and reporting of matters including bribery and corruption. Staff are encouraged to raise matters through line management or to compliance, and can also approach the Integrity Office or anonymously through an externally-hosted staff hotline.

Due Diligence

In dealing with third parties, the Policy requires sufficient due diligence to be undertaken to ensure that they are suitable to be associated with Oxon PTY Limited, and that appropriate controls are implemented, designed to prevent and detect bribery and corruption. Third parties associated with Oxon PTY Limited are in turn expected to have appropriate due diligence arrangements and controls in place in relation to the other parties they engage with, on behalf of Oxon PTY Limited.

Monitoring & Review

Oxon PTY Limited performs payment monitoring, including monitoring for bribery ‘red flags’ and Oxon PTY Limited' independent compliance function conducts periodic risk-based monitoring of gifts and entertainment.

Training & Communication

Oxon PTY Limited promotes staff awareness in compliance with the Anti-Bribery & Corruption framework through the appropriate dissemination of the Policy and procedures (including disciplinary procedures) and training on induction and periodically thereafter

Anti-Money Laundering & Counter-Terrorism Financing Policy

Policy Summary

Oxon PTY Limited is committed to performing its business in agreement with industry laws and regulations, and in a way that maintains and enhances our unique reputation. This policy covers Oxon PTY Limited ’s approach to the identification, mitigation, and management of all risks that the Oxon PTY Limited brand in totality might become associated with, concerning money laundering and corruption.

Description of money laundering and terrorism financing

Oxon PTY Limited defines money laundering (“ML”) as activity which is designed to conceal or disguise the true origin of criminally derived proceeds in order to make them appear to have been sourced from legitimate sources. Terrorist Financing (“TF”) is considered to be the act of providing financial support to terrorism or terrorist organizations to enable them to carry out acts of terrorism.

Objectives of Oxon PTY Limited’s AML/CTF policy

Oxon PTY Limited has established an AML/CTF policy which sets the core principles for the management of ML/TF risk. The policy is global in nature and outlines group-wide standards to meet regulatory and ethical obligations in the economies in which Oxon PTY Limited does business. This contributes to the stability, integrity and strength of the global financial system and protects us from reputational damage.


The core principles

Oxon PTY Limited has adopted the following core principles:

  • Oxon PTY Limited opposes the crimes of money laundering and terrorist financing and maintains a framework to identify and mitigate the risk that its products and services could be used for such purposes.
  • Oxon PTY Limited reports any activity that it detects which is suspicious and may involve potential money laundering or terrorism financing to the applicable regulator.
  • Oxon PTY Limited will comply with the AML/CTF laws, rules and regulations of the countries that relate to AML/CTF where Oxon PTY Limited has permanent places of business through which Oxon PTY Limited provides services.
  • Oxon PTY Limited will endeavor to provide its products and services only for legitimate purposes to customers whose identities has been able to reasonably ascertain.
  • Oxon PTY Limited will take reasonable steps to ensure that sufficient funding and resources are available for the implementation and performance of activities required by Oxon PTY Limited’s AML/CTF Program.
  • Oxon PTY Limited employees are required to attend AML/CTF training to understand their obligations under the relevant laws, rules and regulations.
  • Oxon PTY Limited will monitor its customers, their transactions, and its employees, consistent with the level of money laundering and terrorist financing risk they represent. Oxon PTY Limited will manage new and revised changes to Oxon PTY Limited’s products, business processes and systems to ensure that money laundering and terrorist financing risks are identified and managed.
Oxon PTY Limited’s AML/CTF training program
  • Oxon PTY Limited has a robust AML/CTF Training Program to educate employees in implementing and maintaining Oxon PTY Limited’s AML/CTF Program. All employees undergo initial AML/CTF training when they join Oxon PTY Limited. In addition, there are ongoing training requirements for all employees.
Oxon PTY Limited’s record retention
  • Oxon PTY Limited’s Record Management Policy requires retention of records for as long as required by applicable laws, rules and regulations.
Know your customer (“KYC”)

Oxon PTY Limited endeavors to follow all KYC policies and procedures relevant to the regions in which it operates. Applicable KYC policies and procedures to establish and verify the identity and bonafides of customers will also be complied with.

These will include customer acceptance procedures that identify types of customers and transactions likely to pose a higher than average risk to Oxon PTY Limited and require a higher level of due diligence;

  • Procedures to establish if customers are known or suspected money launderers, terrorists or otherwise engaged in criminal activity (e.g. reviewing customers against government/United Nations/regulators’ lists of proscribed persons)
  • Enhanced Due Diligence undertaken where a transaction or a counter party results in a heightened level of financial crime
  • A risk-based periodic review of existing customer records to maintain currency and completeness
  • Ongoing monitoring of transactions conducted by customers using a risk based approach
  • Procedures prohibiting accounts/relationships, including payment processing, with shell banks
  • A clear statement on what records must be kept on customer identification and individual transactions and their retention period; and
  • Regular compliance reviews and independent audits of AML/CTF program and procedure documents and execution against established standards.
Suspicious activity
  • Oxon PTY Limited staff are trained and made aware of “red flags”, or anything that is unusual or out of the ordinary when dealing with customers and customer related information. Oxon PTY Limited has the relevant procedures and processes in place to ensure that any genuinely suspicious matters are detected and escalated for review by senior management.
Independent review of the AML/CTF program
  • Oxon PTY Limited’s AML/CTF Program is subject to independent review in accordance with the requirements of each local jurisdiction. The results of the review are presented to senior management for review and action. In addition, regular reporting is provided by Compliance to Oxon PTY Limited’s Board

PRESIDENT

Lucas Hamiltion


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President’s Message

Lucas Hamiltion is a financial advisor who first became aware of the stock market when his father purchased a few shares of Church’s Fried Chicken stock for him in the mid 1970’s. The stock was also purchased for his 2 siblings, who eventually sold their stock and took the cash. At the age of 14, Lucas Hamiltion sold his stock as well, but decided to take his proceeds and reinvest. He had a passion for baseball cards at the time, and decided to purchase shares of Topps, a leading baseball card distributor. Over the next few years, Lucas Hamiltion doubled his money and he was hooked.

Always fascinated with numbers, he earned his BBA in Finance from Southwest Texas State University in 1985, with a specialization in Financial Planning. Upon graduation in 1985, he immediately went to work for Fidelity Investments in Dallas, Texas as a mutual fund trader. In just a few months, Lucas Hamiltion’s job expanded to cover all 50 states and he was awarded duties of helping out the sales team at Fidelity.

His opportunity to meet with clients on an individual basis came in 1996, when he became a financial advisor for a growing money management firm in San Antonio, Texas. During his 14 years of dedication to the firm, assets under management grew tenfold and Lucas Hamiltion eventually served as the Chief Trader, in charge of trading millions every day.

This position landed him his own syndicated daily radio show airing in Houston, Dallas, San Antonio, Colorado Springs, & Denver. With the growing popularity of the program, Lucas Hamiltion was invited by various financial news networks for his commentary on the markets as well. Some of the networks on which he has appeared include CNBC, CNBC Asia, Bloomberg, Fox Business, & Reuters. Lucas Hamiltion enjoys offering public discourse on the state of the economy and the financial markets whenever possible.

In 1992, Lucas Hamiltion established Oxon PTY Limited, a registered investment advisory firm dedicated to providing clients with superior financial counsel in the changing economy. His market insight and investment strategies help fulfill the mission of Oxon PTY Limited to help clients in the face of a rapidly changing market.

Other major successes in Oxon PTY Limited’s life include his family. He met his wife Amy in college and they were married in 1997. With their 2 children, Adrain and Avery, Noah and Amy currently reside in Sandpoint, Idaho.

Now let’s talk about Oxon PTY Limited. I’ve always thought that you could learn a lot about an organization by how it responds to change. Does it rigidly stand its ground and eventually lose its relevance? Or does it blow like a seed in the winds of change until it becomes an unrecognizable version of its former self? When it comes to navigating change, I prefer a more grounded, but nimble approach: staying rooted in a timeless principle, while adapting how that principle is brought to life. More and more, I am absolutely convinced that this timeless principle – the very future of financial advice itself – is independent, objective advice.

The aim of these activities is to obtain current market information through continuing market operations and to contribute to the financing of our management costs. These activities enable us to conduct small and large equity transactions in a cost-efficient manner and with low brokerage fees. It is gratifying to note that we earned more than $20 billion as profit investing on Forex and CFD trading, Cryptocurrency, Real Estate, Renewable Energy, Stocks and NFP for the second year in a row, which more than amply covered our management costs.

Through hard work, Oxon PTY Limited’s portfolio have attained leading positions in their respective areas. Their operations have wide international coverage, with strong positions in the world’s largest economies, such as North America, Europe, Australia and Asia – areas that account for more than half of global GDP. Moreover, our portfolio have a growing share of their sales in emerging markets around the world . By looking forward and with a longer time perspective, you can get a feeling for what development and urbanization of the world’s growth countries can entail. The United Nations projects that the world’s population will grow by 20%, to 8.5 billion people, in the coming 20 years – essentially all in growth countries. During the same period, global GDP is expected to double in real terms. Rising prosperity in countries like China, India, Brazil and Russia is creating opportunities for Oxon PTY Limited’s portfolio companies that are active primarily in industrial and infrastructure products, which are key areas associated with rapidly growing prosperity in emerging countries. I am highly confident that Oxon PTY Limited – through their strong positions – have the conditions and ability to capitalize on these opportunities to the benefit of our clients.

Active ownership with focus and flexibility

For an active owner it is of decisive importance to gain a good picture of a portfolio company’s business and business environment, and to have an opinion about the company’s future performance. Global companies are encountering a more competitive and rapidly changing world in many respects. In part, the macroeconomic conditions are shifting between various countries and regions, and in part, a number of rapid shifts are taking place as a result of revolutionary mega trends, including digitization, urbanization and greater focus on sustainability. No company can foresee in detail how these factors will affect their business. However, companies can mitigate their risks and enhance their opportunities if they focus their business on what they are good at and succeed at strengthening their structural flexibility. This can be achieved through greater decentralization, increased financial scope to act, and perhaps most important of all, through continuous improvements in their own operations. As an active owner we believe that a clear business focus, distinct customer orientation and keen ability to adapt are vital factors for being able to generate a competitive return over time.

Satisfactory growth processes but a number of challenges

The macroeconomic conditions from 2019-2022 are expected to remain favorable, and as in 2018, global growth is projected to be around 4%. It can be noted that most of the major economies are now expected to show growth in 2020, although to varying degrees. In the longer term the question is when the economy will level out and at what pace this will happen.

In Europe the recovery has been good, and the political risks have decreased slightly after several elections and the start of Brexit negotiations. Growth in the U.S. remains favorable. It is hard to assess the overall effect of the recent tax reform and possible infrastructure investments, but they are expected to have a positive effects on growth. In China, growth has stabilized at a relatively favorable level. Several emerging countries are benefiting from a weaker U.S. dollar, which has strengthened their competitiveness.

From a geopolitical perspective there are a number of areas of concern that are giving rise to uncertainty region- ally as well as for the global economy. Despite these, a stable macro environment and strong company performance contributed to the stock market’s favorable performance in 2018. Forex, CFD Trading, NFP, Renewable Energy and Real Estate continued to develop positively during the beginning of 2018, but in early February a correction occurred in stocks market and the volatility increased, due to concerns about the US stock market. Although the market has shown a clear concern about rising in action and interest rates, the macro forecasts for 2019/2022, earnings growth for companies and high interest rates, point to an underlying support in the stock market. However, in the future there are expectations of higher interest rates and reduced stimulus measures.

We are broadening our investment universe

Oxon PTY Limited will continue to invest in listed profitable companies with good return potential. Our active ownership will build upon a foundation of trust and ownership based influence. Our share of ownership should therefore be at least 10% of the votes. We are now broadening our investment universe by also looking at slightly smaller companies. For new investments, a candidate should have a minimum market cap of roughly $3 billion. If we invest in a company with a market cap of $3–10 billion, a 20%–30% equity stake is desirable. The idea is to have a genuine position of influence and that the investment’s potential return will make a tangible contribution to the equities portfolio as a whole.

Strong position for competitive returns over time

Oxon PTY Limited is in a favorable position to conduct successful, long-term asset management based on active ownership. Starting from our strengths, a professional organization and the development steps we are now taking, I look forward to leading the business to generate competitive shareholder value over time.

All of us at Oxon PTY Limited are proud of the fact that we’ve been one of the nation’s best investment platform for more than 15 years. That’s a great legacy. But personally, I’m more excited about the next 20 years for Oxon PTY Limited. Working with an extraordinary group of financial advisors to lead the independent advice model into the future is a pretty great opportunity, and I can’t wait to work on that future together with our advisors to generate more profit for our clients.

Regards,