amended 29/03/2026
Formal Proposal: The Retention and Stewardship of the Bouchardon Bust of Sir John Gordon
Date: 27/03/2026
To: The Arts Council / Reviewing Committee on the Export of Works of Art
Subject: A Strategic Proposal for the Long-Term Exhibition and Local Stewardship of the Bouchardon Bust
1. Executive Summary
This document constitutes a formal proposal from the Invergordon Museum to secure the long-term future of the Bouchardon Bust of Sir John Gordon within the United Kingdom. We acknowledge the current application for an export licence; however, we contend that a permanent export at this stage is premature
and would result in a significant loss to the nation’s cultural fabric.
Crucially, we draw the Committee’s attention to a major discrepancy in the current sale proceedings: while the bust is currently positioned for sale at £2.5 million, its updated market valuation stands at £3.1 million. We submit that allowing the export at the lower valuation would not only be a cultural loss but a failure to
reflect the true "fair market value" as intended by the export control system.
2. The Waverley Criteria and National Importance
We maintain that the bust meets the Waverley Criteria on all three counts, making it a pre-eminent candidate for a further deferral:
- Criterion A (History): The bust is of outstanding significance for the study of 18th-century Scottish history and the development of the Highlands. It represents Sir John Gordon, the founder of Invergordon, in a manner that binds the object inextricably to its local and national context.
- Criterion B (Aesthetics): As a masterpiece by Edmé Bouchardon, it is one of the finest examples of Neoclassical sculpture in any British collection. Its departure would be a "misfortune" for the study of European art history within the UK.
- Criterion C (Scholarship): The bust is of fundamental importance for the study of Bouchardon’s oeuvre and the patronage of the Grand Tour.
3. A Sustainable Stewardship and Financial Model
The Invergordon Museum proposes a revenue-generating model that ensures the bust remains accessible to the public while providing a sustainable financial return to the Common Good Fund (the current owners).
The Proposed Agreement:
- Long-Term Loan: The bust would be placed on a long-term loan (e.g., 25–30 years) to the Invergordon Museum, with the Highland Council retaining full legal ownership.
- Public Access & Revenue Sharing: The bust would be the centrepiece of a dedicated, ticketed exhibition. We propose that 75–80% of all ticket revenue be paid directly to the Common Good Fund.
Exhibition Projections: Based on current cruise tourism data for the
Cromarty Firth, we project:
- Annual Visitors: 20,000 (representing a conservative 10% conversion of cruise passengers).
- Annual Revenue: Estimated £75,000 – £80,000 in direct payments to the Fund.
- Total Term Value: Approximately £2.25m – £2.4m over 30 years, allowing the public to benefit from the asset’s appreciation (currently valued at £3.1m) without losing the asset itself.
4. Security and Risk Management
Historically, the "barriers to entry" for local display have been insurance and security. We have addressed these through:
- Government Indemnity: Utilising the Scottish Government’s Indemnity Scheme to provide statebacked insurance, removing the financial burden of commercial premiums.
- National Museum Standards: Our security strategy meets the stringent requirements of national institutions, including state-of-the-art surveillance and physical protection.
5. Conclusion
The Invergordon Museum requests that the Arts Council grants an extension to the deferral of the export licence. This extension is necessary to allow for the reconciliation of the £600,000 valuation gap and to permit the finalisation of this stewardship model. We believe this path offers the best outcome for the public,
the local community, and the long-term preservation of British heritage.
Yours sincerely,
The Trustees
Invergordon Naval Museum and Heritage Centre
140 High Street
Invergordon IV18 0AE
Invergordon Museum is a SCIO
Scottish Charity Number: SC035244
invergordon.museum@outlook.com
INVERGORDON NAVAL MUSEUM & HERITAGE CENTRE
Statement of Case: Valuation Discrepancy and the Public Interest
To: The Secretariat, Reviewing Committee on the Export of Works of
Art (RCEWA)
Reference: The Bouchardon Bust of Sir John Gordon
Date: 27/03/2026
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1. Argument Regarding Fair Market Price
Under the guidance for the export of cultural goods, the "matching price" for a UK institution or stewardship scheme is typically set at the Fair Market Price. We wish to formally submit evidence that the current offer of £2.5 million no longer reflects the true value of the asset.
- Current Valuation: Recent independent assessments place the value of the Bouchardon Bust at £3.1 million.
- The Valuation Gap: There is a £600,000 (24%) discrepancy between the proposed sale price and the current market value.
2. Implications for the Export Licence
If an export licence is granted based on the lower figure of £2.5 million, the Invergordon Common Good Fund—and by extension, the Scottish public—would be deprived of over half a million pounds in potential value.
We contend that the current application is procedurally flawed because:
- It does not reflect the "Net Economic Benefit" to the UK public.
- It creates an artificial "bargain" for an overseas buyer at the expense of the local community’s charitable assets.
3. Request for Extension of Deferral
The Invergordon Museum requests that the Reviewing Committee:
- Stay with the current application until a renewed, independent valuation is verified.
- Extend the deferral period by a further 6 months to allow our stewardship and revenue-sharing model (detailed in the attached proposal) to be fully vetted against this higher valuation.
4. Summary of Position
Allowing the bust to leave the UK for £2.5 million when it is worth £3.1 million is not only a cultural loss but a financial irregularity. A deferral is essential to ensure that the "Common Good" is truly served—either through the retention of a £3.1m asset or through a stewardship model that respects its true worth.
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Yours faithfully,
The Trustees Invergordon Museum and Heritage Centre
Scottish Charity Number: SC035244