Agenda item

The Penthouse Club, 1-4 Walker’s Court, W1F 0BT (24/08227/LISEVN)

1.

Application for a New Sexual Entertainment Venue The Penthouse Club, 1-4 Walker’s Court, W1F 0BT under the Local Government (Miscellaneous Provisions) Act 1982 (as amended by the Policing and Crime Act 2009)

The Sub-Committee has determined an application for a New Sexual Entertainment Venue Premises Licence made by Soho Prime Entertainment Ltd to operate the Premises as a sexual entertainment venue between the hours of Monday to Saturday 10:00 to 03:00 Sunday 12:00 to 22:30 and 12:00 to 03:00 Sundays before a Bank Holiday

Amendments to application advised at hearing: N/A

Decision (including reasons if different from those set out in report):

Reasons:

12 objections were received, including representations from Environmental Health and the Licensing Authority. 2 representations in support were submitted. The objections are set out in full at Appendix B of the Report.

Ms Jessica Donovan, Senior Licensing Officer, outlined the application to the Committee. She advised that this was an application for a New SEV Licence located in the West End Ward and West End Cumulative Impact Zone. She confirmed that they had received representations from the Licensing Authority (LA), Environmental Health Service (EHS), and ten interested parties in objection and 2 interested parties in support. She confirmed that the additional submissions from the Applicant and the Interested Parties had been circulated.

Ms Sarah Le Fevre, Counsel for the Applicant, outlined the application to the Committee. She advised that the premise had the benefit of a premises licence and were requesting an SEV licence with hours and capacity that mirrored their premises licence with extensive conditions. She advised that there had been a degree of confusion from the objecting comments and highlighted that it was not a new licence, and that this application was to determine what sort of entertainment should be provided at the premises. She highlighted that distaste for sexual entertainment was not a reason to take into consideration when making the decision. She advised that SEV premises were heavily regulated and did not negatively impact the area. She noted that the location in the West End, Core CAZ North was an appropriate location for a SEV, and she highlighted that the policy encouraged the widening of the entertainment landscape.

Ms Le Fevre outlined the proposed activity and Applicant to the Committee. She advised that it would be a contemporary entertainment venue with performance, theatre and sexual entertainment. The Applicant would be held to the highest standards in looking after their staff, performers and customers. Performers would be escorted within the premise by highly visible security and would be escorted to a pre-checked and booked vehicle at the end of their shift. She advised that the ground floor would have no entertainment and would be a holding area within the premises where people could queue on arrival and wait for their transport on departure. There would be a high level of security within and outside the venue and they anticipate equipping their security with body worn cameras to assist the Metropolitan Police Service (MPS) with footage if needed. The venue would add positively to the issues of the surrounding area as it would increase illumination and technical coverage of the area. She advised that the application would bring significant investment into the area. Throughout the consultation they had worked with the Licensing Authority (LA) and Environmental Health Service (EHS) and this would continue if the application was granted. She highlighted that the MPS did not make any representations to the application and the MPS were not slow to object to applications were appropriate. The venue would assist the MPS, including with their publicised phone snatching crack down. She highlighted that WCC’s policy determined that the appropriate number of SEV’s in the Borough was 25 and that the number they currently have was significantly below that. She noted that the voices in support of the application include Dr Hadfield, an independent expert, and the Soho Business Alliance who noted that the premise would represent a culturally significant addition to Soho.

In response to questions, the Applicant advised that there was a CCTV camera which covered the entrance and there would be a degree of refurbishment to the property if the application were granted.

Mr James Hayes, representing the LA, advised that they had given the application a significant amount of scrutiny due to it being a new applicant and a new SEV licence. He advised that the Applicant had not been convicted of any crimes and the LA had looked through the operator’s previous trading history and had not found anything alarming. He advised that there were a number of conditions on the licence which would manage the risk of opening a SEV licence in the West End and conditions to protect the performers. The LA had proposed several additional conditions which the Applicant had agreed to, many of them standard conditions. Mr Hayes highlighted conditions 32, 36 and 37 which would help to protect the performers. He also highlighted the locality and noted that the policy stated 25 SEV’s in the Borough while there were only 13 at present. The premise was located on a pedestrianised street and a clear street management plan would be needed.  He advised that later opening hours would have a greater impact on residents but noted that they already had a licence until 03:00hrs so the risk of suggesting core hours for this application could mean greater disturbance to residents. He confirmed that he had had assurances that the premises’ entrance would be on Walkers Court away from residents. He advised that there was a significant concentration of sex shops and SEVs in the area, which the policy allowed.

Mr CR outlined his objection to the committee. He advised that he had been a resident for the last 20 years and in the last 10 years, since the premises had been closed, the surrounding area had become increasingly busy. He advised that the premises would attract a certain client- male, with money to spend, and often intoxicated. These clients would likely become target to drug pushers on the way in and out of the premises. He advised that the premises was located in a busy part of Soho and the increase in customers would increase the number of pedicabs and drug pushers which would disturb the peace at 03:00hrs. He advised that he did not have problem with SEVs but did have a problem with the concentration of SEVs in this location. He noted that the policy stated 25 SEVs allowed but highlighted that this was decided 13 years ago and the area had change significantly since then with Brewer Street now more fashion focused and with a primary school on it. He implored the committee not the grant the licence as it would cause problems for the residents, and they would take up MPS resources from their complaints.

Mr Anil Drayan, representing the EHS, advised the Committee that they had maintained their representation principally to assist the committee in any questions they may have when deciding on the application. He advised that the EHS looked at the application in conjunction with the premises licence which was already until 03:00hrs. He advised that if the premise operated as an SEV many of the issues related to the licensable objectives would occur less than under purely licensable activities to 03:00hrs. He advised the Committee that the licence had sufficient conditions on the sound limiters, noise escape and queuing in the premises and there was a works condition on both premise and SEV licence which the EHS would have to remove before they could operate.

Mr Richard Brown, representing the Soho Society, advised that the SEV legislation confers a wide discretion to the Committee on place making and what they consider appropriate for the area. He noted that the Soho Society had no concerns about the suitability of the Applicant but did about the character of the locality and use of other premises. He advised that they believe there were two misapprehensions of the application:

1.     That premise would have a more benign use in relation to impact than what would be operated under 03:00hrs licence.

2.     That the character of area would welcome a SEV premises.

He highlighted that the premises had not operated for 10 years and in that time there had been two cumulative impact assessments which reinforced the position that Soho had problems with crime and anti-social behaviour. He stated that there was an assumption that an SEV would not have the same intensity as a licensed premise but advised that the premises opposite offered a reduced capacity of 100 when applying to be a SEV while this application still had a capacity of 300 and terminal hour of 03:00hrs. There was also no last entry condition which would aid dispersal. He advised on the locality of the area and highlighted that the Applicant relied on Dr Hadfield’s report but he noted that the report omitted the extent of the residential properties in the area. He agreed with Dr Hadfield’s report on the reality of crime in the area and noted that it was the least safe between 01:00hrs and 04:00hrs which was when the premise would close. The Soho Society struggled with the conclusion that a new 300 cover premium price establishment would help with the area and noted that surrounding establishments SIA’s did not have the power to disperse patrons and they did not see how the Penthouse’s SIAs would have any powers.

Mr Tim Lord, resident, representing the Soho Society, and also as the Chair of the Westminster Safer Community Board advised that in the last 10 years Soho had changed and crime levels had got worse. He asked the Committee to consider the volume of people this premises would have in a hotspot for crime, including serious violent crime. He advised that there were 30 sexual assaults in the West End every month and police were few in the late hours as they start the night with 30 officers and every time anyone is arrested two officers return to the station and do not return to the streets. He advised that the nearby premise The Box Soho attracted groups of criminals and the SIA’s had no power to disperse them. He advised that the Soho Society were concerned about the safety of the dancers and questioned whether the proposal of taking dancers to a waiting car was conditioned and how it would work in practice. He advised that crime had got worst without police presence and the SIA’s did not have the same powers as the MPS. He stated that the location was one of the worst places to open a new SEV premises.

Mr Rupert Power, representing the Soho Business Alliance, advises that he operated a nightclub on Great Windmill Street and believed that this premises would be positive for the community as it would bring over 200 employees to the Soho neighbourhood. This would include 6 security outside the premise who would be beneficial to the area as presence is important. He highlighted that the area had received CIL funding for more CCTV, and this will help the crime problems late at night.

In response to questions, Ms Caroline Kirkendoll (of the Applicant Company) advised that many of their other locations were centrally located and they were not using the entrance on Brewer Street, only the main entrance on Walker’s Court. Mr Thomas outlined where the staff and customers would get a taxi from nearby and advised that performers would be escorted by security to transport and there would be a minimum of 2 SIA’s located at the taxi junction by the end of the night for safety. Ms Kirkendoll advised that performers tended to ride share together or if there were not ample transport options, the company could provide a mini bus for performers to transport links or a parking lot. They advised that they were not expecting big queues as the performances would start earlier and patrons would come gradually. If they did come at one time, there would be ample space in the ground floor which could hold up to 20-25 people in a queue. That said if they did need to queue on the street, they would have a SIA at the beginning and end of the queue on Walker’s Court and they would work with The Box to make sure accessibility was still maintained.

Mr Eddie Suqi (of the Applicant Company) advised on how they would manage refusals and advised that they had a zero tolerance to drug taking. Mr John Kirkendoll advised that in the 38 years they had run premises they had never had any issues with drug taking due to their zero tolerance. Ms Kirkendoll advised that they were not expecting the regular stag do clients and were hoping to target an older and more female demographic with around 40% of patrons being female. She advised on the accessibility of the premise and noted that Brewer Street would only be used as an accessible entrance and they would have accessible lifts and toilets. She suggested that this location, with its crime rates, would be similar to their New Orleans location and advised that they had managed it well and had had no reports of crime to the performers when leaving the premises. They advised that the average entry fee would be £25, and they expect around 40% of their patrons to be pre-booked but they were adjusting their model to have more pre booked tables. While customers could go to the bar for a drink they encouraged customers to sit. Ms Kirkendoll confirmed that there was CCTV in every VIP room and they would be looking at having additional CCTV outside with better lighting. Mr Thomas advised that to help mitigate crime there would be a minimum of 2 SIA’s with body worn cameras outside the premise and would coordinate with The Box to help reduce crime. They agreed to a condition on body worn cameras being worn by SIA stationed outside the premises. 

In response to further questions, the Applicant and Interested Parties discussed the use of taxis for patrons and performers and Mr Tim Lord advised that he had never seen a taxi waiting at the taxi rank highlighted by the Applicant at night as they do not like coming to Soho at night. The Soho Society also highlighted the significant cost of performers using taxis after every shift and the Applicant advised that they tend to share the taxis with other performers and they get paid well. The Applicant also highlighted that taxis tended to congregate where there was demand for them and it was likely that they would come towards the premises due to the clientele. Dr Hadfield advised on the location and that more supervision, which the premises would provide, would be beneficial. Mr Hayes advised that there were conditions on the licence regarding dispersal but that these could potentially be strengthened in relation to performers leaving the premises.

In response to questions from the Legal Advisor, Ms Le Fevre advised that they were likely to have a capacity of 25 in the smoking area but they anticipated less than that. Mr Thomas advised that the previous licence had a last entry time as their entrance was on Brewer Street and nearer to residents, so with the entrance for this premise being on Walker’s Court they did not have the intention to have a last entry time. They had two or four performers throughout the night on the main stage with performances every 45 minutes starting at 23:00hrs with the last performance starting at around 01:30hrs. They advised that the main focus would be on the stage and they would not have a dance floor. They were also expecting minimum spends on the premium tables as they were hoping to capture the guests for the whole evening and guest experience was at the heart of the management team.

In summing up, Mr Richard Brown advised the Committee that a number of the objections to this application detailed what it was like living in Soho and that it would not be right to have a 300 capacity 03:00hrs SEV licence in the area. With the type of clientele the premise would attract, it would attract criminals. The Soho Society would like to see a reduction of capacity due to it being a SEV but this had not been offered. He highlighted that the safety of performers was paramount to the Soho Society and the suggestions from the Applicant were not conditioned. He noted that the Applicant stated that the last performance would be at 01:30hrs so suggested a last entry time in line with this.

Mr Tim Lord, in summing up, advised that there would not be taxis in the taxi rank at 03:00hrs and there were many instances where patrons in Soho had been unable to get a taxi and had subsequently been followed by criminals. Mr Lord highlighted that the performers pay a house fee so the additional costs of a taxi would likely make them consider other forms of transport.

In summing up, Mr Anil Drayan advised that the Committee were aware of the issues in the area and that it is up to them to decide if the nature of the operation and the plans for the running of the outside area would sufficiently mitigate the concerns. He advised that some of the conditions had been changed and it could be conditioned in such a way for the LA to review the management policies if needed.

Mr James Hayes in summing up advised that the committee had more discretion in relation to SEV applications than licensable activities applications. He advised that a SEV had to be reviewed annually and therefore giving some protection to the committee if it was not run well. The MPS and residents regularly objected to a renewal if there was a problem. Mr Hayes highlighted the large residential population of 480 and advised that the LA had tried to address this with their conditions. He highlighted the welfare conditions and welcomed any additional conditions the committee felt were needed including a last performance and body worn cameras and suggested MC06 in that regard.

Ms Le Fevre in summing up advised that the application had been made by a responsible, informed and knowledgeable operator which would sit well within the community. She highlighted that there had been no responsible authorities objecting to the application and they would continue to work with them as the premises started to operate. She advised that the application was within the framework of the extant licence, and this would add higher regulation to the licence which would be reviewed annually. Ms Kirkendoll advised that safety was paramount to the Applicant Company and they had had zero incidences in their similar location in New Orleans as they had taken the steps to ensure the safety of everyone. She highlighted that the house fees for performers would be no more than £50 a night and the earlier they arrive they less they would pay. Mr Thomas advised that the location had always had a premises licence and the impact of it operating as a 03:00hrs nightclub would be worse than a SEV due to the increased supervision and regulations on a SEV licence.

The Sub-Committee, having considered all the representations made both orally and in writing and having had regard to the Council’s SEV Statement of Licensing Policy 2012 (“the SEV Policy”), decided to grant the application with the conditions set out at Appendix E of the report with the following amendments:  

1.     An additional condition shall be imposed as follows:  

The licencee shall ensure that:  

a.              All licensed SIA door staff on duty stationed outside the premises shall be equipped with Body Worn Video (BWV), capable of recording audio and video in any light condition as per the minimum requirements of the Westminster Police Licensing Team.  

b.              All recordings shall be stored for a minimum period of 31 days with date and time stamping, and  

c.               Viewing of recordings shall be made available immediately upon the request of police or authorised officer throughout the preceding 31-day period.  

2.     Condition 29 is varied so that the final bullet point is amended to read as follows: ‘Dispersal of patrons, staff and performers leaving the premises.’  

The Sub-Committee did not consider that there were any concerns about the suitability of the applicant. The Sub-Committee also did not consider that the business would be managed by or carried on for the benefit of a person, other than the applicant, who would be refused the grant of such a licence if he made the application himself.  

The Sub-Committee noted that the number of sexual entertainment venues permitted within the Council’s SEV Policy had not been exceeded. 

Finally, the Sub-Committee considered that that the grant of the licence would not be inappropriate, having regard— 

(i)to the character of the relevant locality; or 

(ii)to the use to which any premises in the vicinity are put; or 

(iii)to the layout, character or condition of the premises in respect of which the application is made. 

The Sub-Committee considered the objections that had been made and noted the serious concerns that had been raised in relation to crime and public safety. However, the Sub-Committee considered that the applicant was a responsible, professional and experienced operator and had agreed robust and stringent conditions that would mitigate the concerns raised. The Sub-Committee noted that the MPS had not made any representation objecting to the application. The Sub-Committee agreed with the submissions made by the applicant that introducing further surveillance and SIA door security staff into this area would help promote public safety and prevent crime and disorder. If the applicant did not comply with the strict and robust conditions that had been agreed, the Sub-Committee noted that this could be raised as a point of objection in any subsequent renewal application.  

The Sub-Committee also considered that the grant of the licence would not be inappropriate given that the premises was located in an area with other SEVs and in the area that had been deemed most appropriate for SEVs in Westminster in the SEV Policy. The Sub-Committee did not consider based on the evidence provided that granting the licence would lead to an over-saturation of SEVs in the locality. In its determination of the matter the Sub-Committee considered all relevant factors namely the locality of the venue and its surrounding premises such as schools and places of worship.  

The Sub-Committee, therefore, granted the Sexual Entertainment Venue Licence subject to the Standard Conditions applicable to licences for sex establishments in Westminster as prescribed by the Council pursuant to Paragraph 13 of Schedule 3 to the Local Government (Miscellaneous Provisions) Act 1982 and the additional conditions imposed on the Licence as specified below.

Standard Conditions

1.        Whilst Relevant Entertainment is taking place no person under the age of 18 shall be on the licensed premises and a clear notice to that effect shall be displayed at the entrance in a prominent position so that it can be easily read by persons entering the premises.

2.        Whenever persons under the age of 18 are admitted to the premises there will be no promotional or other material on display within the premises which depicts nudity or partial nudity.

3.        The licence or a clear copy shall be prominently displayed at all times so as to be readily and easily seen by all persons using the premises.

4.        No provision of relevant entertainment, or material depicting nudity or relevant entertainment, shall be visible from outside the premises.

5.        Menus and drinks price lists shall be clearly displayed at the front entrance of the club, reception area, tables and bar at such a position and size as to be easily read by customers. This price list shall show all consumable items and any minimum tariff including charges and fees applicable to Performers.

6.        Except with the consent of the Licensing Authority, no advertisements of any kind (including placard, poster, sticker, flyer, picture, letter, sign or other mark) shall be inscribed or affixed at the premises, on the surface of the highway or on any building, structure, works, street furniture, tree or any other property or be distributed in the street to the public that advertises or promotes the relevant entertainment at the premises.

7.        The licence holder or other person concerned in the conduct or management of the premises shall not seek to obtain custom by means of personal solicitation or touting, nor enter into any agreement with a third party to do so.

8.        Adequate toilets, washing and changing facilities for use by the Performers shall be provided.

9.        Either the licence holder or a named responsible person shall be present throughout the time the Relevant Entertainment takes place.

10.      The premises will install and maintain a comprehensive CCTV system as per the minimum requirements of a Westminster Police Crime Prevention Officer that ensures all areas of the licensed premises are monitored including all entry and exit points will be covered enabling frontal identification of every person entering any light condition. All cameras shall continually record whilst the premises is open for licensable activities and during all times when customers remain on the premises. All recordings shall be stored for a minimum period of 31 days with date and time stamping. Recordings shall be made available immediately upon the request of Police or authorised officer throughout the preceding 31 day period together with facilities for viewing

11.      A staff member from the premises who is conversant with the operation of the CCTV system shall be on the premises at all times when the premises is open to the public and this staff member should be able to show Police recent data and footage with the absolute minimum of delay of the request.

12.      An incident log shall be kept at the premises, and made available on request to the Licensing Authority or the Police, which will record the following: (a) all crimes reported to the venue; (b) all ejections of patrons; (c) any complaints received; (d) any incidents of disorder; (e) seizures of drugs or offensive weapons; (f) any faults in the CCTV system or searching equipment or scanning equipment; (g) any refusal of the sale of alcohol; (h) any visit by a relevant authority or emergency service; (i) any breach of licence conditions reported by a Performer

13.      The licence holder shall produce a Code of Conduct setting out rules and obligations between the licence holder and performers whilst performing. All Performers shall sign the Code of Conduct in their proper name acknowledging that they have read, understood and are prepared to abide by the said Code of Conduct, and a copy so signed shall be retained by the licence holder and shall be readily available for inspection by the Police and/or authorised persons upon reasonable request.

14.      Individual records shall be kept at the premises of the real names, stage names and addresses of all Performers working at the premises. The record will include either a copy of their birth certificate, current passport, EU driving licence or national identity card and shall be made immediately available for inspection by the Police and/or the Licensing Authority upon request.

15.      Details of all work permits and/or immigration status relating to persons working at the premises shall be retained by the licence holder and be readily available for inspection by the Licensing Authority, a Police Officer or Immigration Officer.

16.      Relevant entertainment shall be given only by performers and the audience shall not be permitted to participate in the relevant entertainment.

17.      There shall be no physical contact between Performers whilst performing.

18.      Performers will not request or give out any telephone number, address or any other contact information from or to any customer. Any such information given by a customer shall be surrendered to the premises manager as soon as is practicable.

19.      Relevant Entertainment shall take place only in the designated areas approved by the Licensing Authority as shown on the licence plan. Arrangements for access to the dressing room shall be maintained at all times whilst Relevant Entertainment is taking place and immediately thereafter.

20.      Customers must remain fully clothed at all times. The Performer must not remove any of the customer’s clothing at any time.

21.      Where relevant entertainment is provided in booths, or other areas of the premises where private performances are provided, the booth or area shall not have a door or other similar closure, the area shall be constantly monitored by CCTV, and access to the booth or other area shall be adequately supervised. There shall be door staff on duty near the booths at all times when they are in use.

22.      Whenever Relevant Entertainment is being provided there shall be no physical contact between Performers and customers or between customers and Performers except for the exchanging of money or tokens at the beginning or conclusion of the performance and only for the purpose of that performance. Clearly legible notices to this effect shall clearly be displayed in each private booth and in any performance area.

23.      Performers must redress fully immediately after each performance.

ADDITIONAL CONDITIONS

24.      Notwithstanding standard condition 17, contact in order to perform skilled dance or acrobat routine is permitted, however this will be limited to performances on the stage area only. For the avoidance of doubt this condition does not relate to performances that are provided solely or principally for the purpose of sexually stimulating any member of the audience anywhere on the premises. 

25.Whenever Relevant Entertainment is provided at the premises, there must be:

a. a minimum of 2 SIA licensed door supervisors on duty at the front entrance to the premises; and

b. at least one SIA registered door supervisor stationed in each of:

(i) the upper basement mezzanine main licensed area; and

(ii) the lower basement licensed area.

26. Whenever Relevant Entertainment is provided in the private booths on the upper basement mezzanine, there must be a minimum of one additional SIA registered door supervisor stationed in that area.

27. No Relevant Entertainment shall take place until the capacity of the premises has been assessed by the Environmental Health Consultation Team and a condition detailing the agreed capacity has replaced this condition, subject to the overall capacity not exceeding 300 persons (excluding staff) at any one time.

28. No Relevant Entertainment shall take place until the premises has been inspected to the satisfaction of the Environmental Health Consultation Team.

 29. The licensee will adopt a street management plan and all customer facing staff including door supervisors shall be trained on the implementation of the plan. The date and attendees of such training is to be recorded and retained for at least 18 months and made available to the relevant authorities on request. Such a plan to include the following:

·       Queuing outside the premises

·       Supervision of a designated smoking area (including a capacity of 25)

·       Prevention of nuisance caused by customers smoking

·       Ordering taxis from inside the premises, where requested

·       Encouraging patrons waiting for taxis to remain inside the premises, where requested

·       Dispersal of patrons, staff and performers leaving the premises.

30. A direct telephone number for the manager on duty at the premises shall be publicly available at all times the premises is open. This telephone number is to be made available to residents and businesses in the vicinity.

31. The Licence Holder shall devise, implement and maintain a Training Regime for:

a. All staff (including self-employed performers) working in customer facing roles at the Premises; and

b. All SIA licensed door supervisors engaged by the Premises.

32. Staff (including self-employed performers) and SIA licensed door supervisors shall not be permitted to commence work at the Premises until such time as they have undergone induction training. The Training Regime shall, as a minimum, cover the following:

a. The hours and conditions of this SEV Licence;

b. The Licensing Objectives for Sexual Entertainment Venues;

c. The Premises’ Welfare and Safeguarding Policy; &

d. Identifying and safeguarding intoxicated and vulnerable individuals (alcohol and prohibited substances).

33. All training at the premises shall be dated and signed off in writing by the Licence Holder. A record of such training shall be kept on the premises for inspection by authorised officers of the council and the Police.

34. Training Records shall be kept for customer facing staff selling alcohol including door supervisors. A record of such training shall be kept on the premises for inspection by authorised officers of the council and the Police during all trading hours. Training records shall be kept for a period of 18 months from the date on which the training was delivered.

35. Performers shall be trained on the Code of Conduct. A record of such training shall be kept on the premises for inspection by authorised officers of the council and the Police during all trading hours. Training records shall be kept for a period of 18 months from the date on which the training was delivered.

36. The Licence Holder shall devise, implement and maintain the following policies in relation to the provision of relevant entertainment at the Premises:

a. Customer Complaints Policy

b. Welfare and Safeguarding Policy, including a Performer Welfare Policy

c. Noise Management Policy

d. Drugs Policy

e. Performers and Staff Complaints Policy

f. Code of Conduct

Copies of these policies shall be kept at the Premises and made available for inspection by authorised officers of the council and the Police on request.

37. The Licence Holder shall designate a member of staff as responsible for staff and dancers welfare at all times that the Premises are open for relevant entertainment and for a period of 30 minutes after the Premises closes to customers. The designated staff member shall be identifiable at all times when on duty.

38. All staff engaged outside the entrance to the premises, or supervising or controlling queues, shall wear high visibility identification.

39. A door supervisor is to remain 30 minutes after the cessation of licensable activities to ensure that customers immediately disperse away from the premises.

40. The licencee shall ensure that:  

a. All licensed SIA door staff on duty stationed outside the premises shall be equipped with Body Worn Video (BWV), capable of recording audio and video in any light condition as per the minimum requirements of the Westminster Police Licensing Team.  

b. All recordings shall be stored for a minimum period of 31 days with date and time stamping, and  

c. Viewing of recordings shall be made available immediately upon the request of police or authorised officer throughout the preceding 31-day period.  

Informative

Definitions

Relevant Entertainment is defined as:

(a) any live performance or

(b) any live display of nudity

which is of a nature that, ignoring financial gain, it must reasonably be assumed to be provided solely or principally for the purpose of sexually stimulating any member of the audience (whether by verbal or other means).

Performer is defined as any person operating at a sexual entertainment venue who carries out any activity falling within the definition of Relevant Entertainment.

The Licensing Sub-Committee

27 February 2025