Appendix D
Dear Sgt. Redbourn,
Thank you for your detailed representation regarding our premises licence application for The Sushi Co (Brighton). We fully respect the role of Sussex Police as a responsible authority and welcome the opportunity to respond to the concerns raised.
At the outset, I wish to express my sincere apologies for the misunderstanding and tone during the telephone conversation on 7 November 2025. It was never our intention to be dismissive of Licensing Officers or Police Licensing, and I regret that our comments created that impression. Since receiving your warning, we have taken immediate corrective action, ceased all late-night hot food sales, and implemented internal compliance procedures to ensure full adherence to the Licensing Act going forward.
We value a positive and cooperative relationship with Sussex Police and the Licensing Authority, and I hope this response demonstrates our commitment to responsible operation.
Following your visit, we acknowledge the following:
· Staff incorrectly advised that we were authorised to operate until 03:00
· Hot food was being prepared after 23:00
· Our public advertising displayed extended hours across various platforms
These issues were the result of internal miscommunication and operational inexperience in this new location—not a deliberate intention to bypass licensing requirements.
Immediate corrective actions taken:
· All advertising and online opening hours have been standardised
· Staff have received revised training on licensing rules
· A temporary restriction has been imposed so no trading occurs after 23:00
· A compliance lead within the company now oversees all licensing matters
· We fully accept that a Late-Night Refreshment Licence is required and have acted accordingly.
We accept that several parts of the submitted application were unclear. We provide the following clarifications:
This was an administrative error and we acknowledge the 28-day consultation period.
Our intention is on-sales only, and we are content for this to be conditioned formally.
After 23:00 the premises would be closed to the public, with refreshments available for delivery only (Uber Eats, Deliveroo). We are fully prepared to accept a condition confirming this.
The correct retention period will be 31 days, and we will abide by this requirement.
The basement is intended for non-alcohol area, storage and staff use only. We do not intend to use it for licensable activities and we welcome a condition excluding it if necessary.
While the DPS lives in Mitcham, they oversee multiple sites and attend Brighton frequently. We can also appoint a local day-to-day manager if this is preferred by the Authority.
We fully acknowledge the premises lie within the Cumulative Impact Zone and that applications are generally refused unless exceptional circumstances are demonstrated.
We respectfully submit that the following factors rebut the presumption of refusal:
The Sushi Co is not a bar, takeaway hotspot, or premises that encourages alcohol-led activity.
· Alcohol is ancillary to food only
· No vertical drinking
· No promotions, happy hours, or high-strength sales
· No environment that fosters extended drinking
Late-Night Refreshment beyond 23:00 is solely to meet
delivery demand.
This does
not contribute to street congregation or noise, and we
propose a condition that after 23:00:
· The premises is closed to the public
· All orders are delivery only
· No walk-ins or collections permitted
We are fully prepared to accept any conditions deemed necessary, including:
· On-sales alcohol only
· Alcohol only served with substantial food
· Staff training every 6 months
· Challenge 25
· Digital CCTV with 31-day retention
· Incident and refusal logs
· Delivery-only model after 23:00
· Joining Brighton Crime Reduction Partnership
· Engaging in ongoing consultation with Police Licensing
Our business model is consistent with low-risk, low-impact
restaurant operations.
We neither
generate nor attract the behaviours associated with alcohol-related
crime and disorder.
We do not
serve alcohol late into the night, and our request does not include
off-sales.
We acknowledge we should have responded promptly to the warning email issued on 10 November and should have contacted Police Licensing to discuss the application. This was an oversight which we regret.
Moving forward, we are committed to full transparency and proactive communication with both Sussex Police and the Licensing Authority.
We understand and respect the concerns highlighted in your representation. We hope that the explanations, corrective actions and willingness to accept stringent conditions demonstrate:
· A genuine commitment to compliance
· A low-risk, food-led operational model
· A clear set of exceptional circumstances
· A sincere intention to build a constructive relationship with Sussex Police
We respectfully ask the Licensing Panel to consider granting the application with appropriate conditions, particularly those restricting late-night activity to delivery only.
Thank you for taking the time to review our response. We remain fully willing to meet with Sussex Police to discuss any further concerns or to agree suitable conditions before the hearing.
Thanks
Hi
Thank you for your letter dated 2 December 2025 outlining the Licensing Authority’s representation regarding our application for a new Premises Licence for The Sushi Co (Brighton) Ltd. We appreciate the opportunity to respond to the concerns raised.
Firstly, we wish to sincerely apologise for the
misunderstanding during your visit on 7 November
2025.
It was
never our intention to operate in breach of Licensing regulations
or to show disrespect to any officer. We fully recognise the
importance of upholding licensing objectives and working
cooperatively with both the Licensing Authority and
Police.
Following your email of 14 November, we immediately reviewed our processes and instructed all staff to cease the sale of any hot food after 23:00. We can confirm that no further late-night trading has taken place since that date.
We regret the confusion caused regarding the “20% hot food” belief. This was based on incorrect internal advice, and we now fully accept that this exemption does not apply. We are committed to ensuring full compliance going forward.
Regarding the staff's comment about the premises being open until 03:00, this was a misunderstanding internally as the application was in progress; we have corrected this and implemented clear operational guidance.
We appreciate that the premises lie within the Cumulative Impact Zone (CIZ) and that applications within this area must demonstrate they will not add to existing problems of crime, disorder, or public nuisance.
We respectfully submit the following mitigating factors and exceptional circumstances:
The Sushi Co operates as a food-led premises, not a bar, takeaway hotspot, or alcohol-focused venue.
· Alcohol sales are ancillary to food.
· We do not attract large crowds or promote late-night social drinking.
· Our customer base is primarily local residents, office workers, and delivery platforms (Uber Eats, Deliveroo).
This differs significantly from high-risk premises typically contributing to cumulative impact.
We are willing to accept conditions including:
· Alcohol only with substantial food.
· No vertical drinking, no bar seating.
· No off-sales after 23:00.
· No high-strength alcohol, no single-item sales, no promotions.
· Full staff training and Challenge 25 policy.
These conditions prevent the premises from adding to crime or anti-social behaviour.
Our request for Late-Night Refreshment until 03:00 is
primarily to support delivery partners rather than walk-in
customers.
This aligns
with the changing nature of food service in the city, where demand
for delivery after 23:00 remains strong but does not generate
public congregation or street noise.
To address public nuisance concerns:
· We will restrict late-night service to delivery platforms only if required.
· No customers will be permitted to enter or collect after 23:00.
· Delivery drivers will be managed to avoid idling, noise, or disturbance.
This ensures minimal additional impact on the night-time economy footprint.
Since receiving your communication, we have put in place:
· A full compliance audit of all licensing procedures
· Updated staff training
· Internal licensing handbook
· Appointment of a dedicated compliance manager
We hope this demonstrates our commitment to meeting the Licensing Authority's expectations.
The initial operating hours on the food registration form
(11:00–23:00) reflected the early operational plan before we
decided to extend hours to meet business needs.
We
acknowledge that we should have notified the Council of this change
sooner, and we apologise for the oversight. This was an
administrative misunderstanding rather than intentional
nondisclosure.
We fully understand the Licensing Authority’s responsibility to protect the CIZ and ensure that any new premises do not contribute to crime, disorder, or nuisance.
We hope the above measures demonstrate that:
· Our operation is low risk and food-led
· We are willing to adopt strict conditions
· We have taken corrective action after the November visit
· We are committed to cooperative and compliant operation
We respectfully request that the Licensing Panel consider these exceptional circumstances and the robust conditions we are prepared to accept, and allow our application to proceed.
We welcome the opportunity to discuss any additional conditions that may help reassure the Licensing Team or Police.
Thanks