1. Purpose
This policy sets out Murzo Group's approach to cultural property, antiquities, artworks, archaeological items, historic objects, ethnographic objects, heritage assets, sacred objects, archival material, and other culturally significant goods.
The purpose is to prevent unlawful trade, protect cultural heritage, reduce money laundering and sanctions risk, support responsible ownership and custody, and ensure provenance, title, export, import, and transfer decisions are properly documented.
2. Scope
This policy applies where Murzo Group considers acquiring, selling, importing, exporting, storing, displaying, loaning, consigning, valuing, transporting, researching, photographing, insuring, restoring, disposing of, or otherwise handling cultural property or cultural objects.
It applies to ancient artefacts, archaeological items, antiques, manuscripts, maps, archives, artworks, religious objects, tribal or indigenous objects, coins, jewellery, weapons, furniture, textiles, fossils, natural history specimens, and objects made from protected animal or plant material.
3. Core Principles
Murzo Group will take a cautious, documented, and ethics-led approach to cultural property.
- Do not acquire, sell, move, or handle cultural objects where lawful title, provenance, or export status is unclear
- Do not knowingly deal in stolen, looted, illegally excavated, illegally exported, conflict-linked, forged, misdescribed, or unlawfully trafficked objects
- Apply enhanced due diligence to objects from conflict zones, source countries with heritage restrictions, recent excavations, politically exposed persons, high-value transactions, anonymous sellers, or complex ownership chains
- Respect cultural, religious, community, indigenous, and source-country sensitivities
- Escalate uncertainty before accepting custody, making payment, publishing, shipping, or transferring ownership
4. Provenance & Title Due Diligence
Before Murzo Group accepts, acquires, sells, loans, exports, imports, or stores a cultural object, it should obtain and review appropriate provenance and title evidence.
Evidence may include bills of sale, ownership history, auction records, collection records, export licences, import documents, customs records, insurance schedules, restoration records, publication history, photographs, expert reports, artist or maker information, excavation history, and source-country permissions.
5. Red Flags
The following red flags require escalation and may require refusal, further checks, independent expert advice, legal advice, or authority contact.
- No ownership history, vague provenance, sudden appearance on the market, or gaps after 1970 for high-risk categories
- Evidence of recent excavation, looting, damage, removed inventory numbers, altered labels, false paperwork, or inconsistent descriptions
- Seller refuses identity checks, insists on secrecy, requests unusual payment routes, or cannot explain ownership
- Object is linked to a conflict zone, sanctioned person, politically exposed person, state collection, museum theft, religious site, burial context, protected heritage site, or source-country export ban
- Object includes ivory, horn, shell, exotic leather, coral, timber, feathers, bone, or other CITES-sensitive material
- Object may be a weapon, military item, dual-use item, human remains, sacred object, or controlled archive
6. Export, Import & Cultural Licences
Cultural objects may require export licences, import permits, customs declarations, CITES permits, source-country permissions, sanctions checks, or other authority approvals before movement.
Murzo Group must not ship, export, import, re-export, hand-carry, post, loan, or temporarily move cultural objects until required checks are completed and relevant licences or permits are in place.
7. Acquisition, Custody & Refusal
Murzo Group may refuse, pause, return, quarantine, segregate, or decline to handle any object where provenance, title, authenticity, legality, safety, sanctions status, customs status, or ethical status is unclear.
Acceptance of custody does not mean Murzo Group accepts ownership, authenticity, lawful title, exportability, marketability, or cultural legitimacy.
8. Loans, Display & Publication
Objects displayed, published, photographed, researched, or loaned by Murzo Group should have appropriate permission, attribution, provenance review, cultural sensitivity review, and security controls.
Public descriptions must not overstate authenticity, age, origin, ownership, cultural significance, legality, valuation, or authority approval.
9. Repatriation, Claims & Authority Contact
Claims from source countries, communities, museums, former owners, law enforcement, customs authorities, insurers, or other parties must be escalated promptly.
Murzo Group may preserve records, suspend movement, restrict sale, obtain legal advice, cooperate with lawful authority requests, or support appropriate return or restitution where justified.
10. Records, Review & Responsibilities
Murzo Group will maintain object files containing provenance, title, due diligence, condition, images, valuations, permits, movement history, custody records, insurance, decisions, and correspondence.
Directors, asset owners, procurement leads, logistics contacts, compliance leads, collection managers, and authorised representatives are responsible for applying this policy. It will be reviewed periodically and after legal, market, cultural, or operational changes.
