HOSPITALITY MATTERS CURRENT TOPICS IN THE INDUSTRY

CMS Cameron McKenna

Spring 2012 Contents

Page 4 Page 6 Page 9

SHOWING LIVE SPORT USING UK DEVELOPMENT ROUND UP UP COMING EVENTS FOREIGN TV DECODERS

Page 10 Page 12 Page 13

ENVIRONMENTAL MATTERS UK EMPLOYMENT LAW ISSUES HOTEL HOT TOPICS AFFECTING EUROPE

Page 14

RECENT TRANSACTIONS

Hospitality Matters is prepared by the & Leisure group of CMS Cameron McKenna. It should not be treated as a comprehensive review of all developments in this area of law or of the topics it covers. Also, while we aim for it to be as up-to-date as possible, some recent developments may miss our printing deadline.

This newsletter is intended for clients and professional contacts of CMS Cameron McKenna.

It is not an exhaustive review of recent developments and must not be relied upon as giving defi nitive advice. The newsletter is intended to simplify and summarise the issues which it covers.

2 | WELCOME HOSPITALITY MATTERS Welcome

Welcome to the third edition of Hospitality Matters, our regular bulletin for the hotels industry. This edition is being launched just as the European hotel investment sector Thomas Page de-camps to Berlin for three days for IHIF 2012. Head of Hotels & Leisure group T +44 (0)20 7367 3046 One of the hot topics to be discussed in Berlin will be how we reconcile the two-speed E [email protected] economies that have emerged over the last year. At the European level we have a two- speed regional economy with the Mediterranean countries paralysed by sovereign debt issues and economies reversing due to strict austerity measures, while Northern Europe is less affected.

In the UK and we have a two-speed hotel market, with London and Paris continuing to trade as though nothing is wrong with the world, leaving the provinces to suffer from the economic realities of stagnant growth, and ever increasing operating costs.

The fl ight to quality is driving activity in the successful markets for those investors looking for a secure place to park their capital. Meanwhile the distressed sales continue to fl ow slowly and steadily from the less successful markets, giving those investors with more appetite for risk opportunities to pick up assets at the bottom of the economic cycle.

Whichever you are looking for, happy hunting!

3 Showing live sport using foreign TV decoders

Tom Scourfi eld Stuart Helmer Partner Associate T +44 (0)20 7367 2707 T +44 (0)20 7367 2687 E tom.scourfi [email protected] E [email protected]

Pubs and hotels that wish to shop around European countries to fi nd the most cost-effi cient way of showing sports matches to their customers have suffered a setback following a recent decision from the Court of Justice of the European Union (CJEU).

In the joined cases of Football Association Premier League relevant subscribers. The FAPL licence prohibits the Ltd v QC Leisure et al and Karen Murphy v Media Protection broadcasters from supplying decoder cards outside the Services Ltd, the CJEU ruled that pub landlady, Karen Member State for which the licence is granted. Murphy, could no longer continue to use a Greek BSkyB decoder to screen live Premiership Football matches in her These cases concern attempts to circumvent that English pub, on the basis of copyright infringement. This exclusivity. In the fi rst case, the FAPL brought proceedings decision will prevent pubs, bars and hotels in the EU from against the two Greek companies which exported Greek showing copyrighted parts of the broadcast using decoder decoder cards and sold them in the UK. The FAPL also cards from countries outside their own. brought proceedings against the British publican Karen Murphy who purchased a Greek decoder card to show There was some good news for individual sports fans as Greek broadcasts of live FAPL football to her customers in they may continue to shop around within Europe for order to avoid paying the higher UK subscription fees. From foreign decoders for such broadcasts. The CJEU has ruled these two joined cases, the English High Court referred a that it is not illegal for customers to buy set-top box number of questions concerning the interpretation of decoder cards from foreign broadcasters, and that the European Union law to the CJEU. Football Association Premier League (FAPL) cannot stop individuals from seeking better foreign deals for TV sports subscriptions than those offered by BSkyB. CJEU decision

The CJEU held that the system of licences for the broadcasting Background of football matches is contrary to EU competition and free trade laws and cannot be justifi ed in light of the objective of The FAPL markets the television broadcasting rights for protecting intellectual property rights. English Premier League matches and grants exclusive live broadcasting rights for the matches on a territorial basis, However, the court also ruled that screening football match under an open competitive tender procedure. Each broadcasts using a Greek decoder card in a pub was broadcaster must encrypt its signal so that viewers can unlawful on the grounds of copyright infringement, as it watch only the matches transmitted by the broadcasters constituted broadcasts of ‘protected works’ without licensed to show the matches in the Member State where authorisation. Although there is no copyright in the they reside. Broadcasters issue decoder cards to the matches themselves, there being no copyright in live sport,

4 | SHOWING LIVE SPORT USING FOREIGN TV DECODERS HOSPITALITY MATTERS the FAPL anthem, opening video sequences, pre-recorded The combined effect of these decisions is that transmitting fi lms showing highlights of other FAPL matches and live sport broadcasts, obtained through a foreign decoder on-screen graphics were ‘protected works’, which would card, to either the rooms in a hotel or the hotel’s restaurant attract copyright protection. or bar would be likely to constitute copyright infringement. Hotels are best advised to purchase only decoders for the The transmission in a pub of the broadcasts containing territory in which the hotel is located and to ensure that the those protected works would constitute a ‘communication terms of their licences cover the intended use of the broadcasts. to the public’ within the meaning of the Copyright Directive 2001/29/EC, for which the authorisation of the author of the works is necessary. When a pub transmits those works to its customers the works are transmitted to CMS Comment an ‘additional public’, being the pub customers, who were not considered by the authors when they authorised the Whilst this decision is not surprising in many ways, we broadcasting of their works. Therefore, in practical terms, are disappointed that the European Union principles of the showing of such broadcasts in venues such as pubs, free movement of goods and services can be so easily bars and hotels would likely always infringe copyright. In defeated by copyright in the ancillary parts of the contrast, viewing by private individuals using imported broadcast. decoder cards will not necessarily infringe copyright. Although the High Court’s ruling at the end of February has largely been publicised as a success for Practical implications for hotels Karen Murphy, in that pubs cannot be fi ned simply for using cut-price foreign decoders, the FAPL will likely For hotels, bars and pubs, shopping around Europe for a now seek action for breach of copyright due to the cheaper foreign decoder may not be a viable option. The inherent diffi culties in televising football matches to inclusion of copyrighted elements throughout the customers without also televising the copyrighted broadcast make it diffi cult for such foreign broadcasts to elements contained within such broadcast. be broadcast publicly without infringing copyright. We do not expect these types of issues to be resolved soon and rights holders may continue to be able to The hotel industry needs to be aware that the transmission maintain differential pricing across EU countries for of broadcasts to hotel rooms as well as bars and lobbies many types of intellectual property, despite the ruling also constitutes a potentially infringing ‘communication to that such practice is contrary to EU competition and the public’. This was established by a CJEU decision in free trade rules. 2006, SGAE v Rafael Hoteles SA, in which the court held that the distribution of a signal enabling broadcasts to be communicated by television sets in hotel rooms constitutes a ‘communication to the public’. The clientele of a hotel are not the intended direct users to whom the author of the work authorises broadcasting.

5 UK development round up

Until recently it had long been settled practice that generally a development could not be restrained because of its effect on rights of light (or other private rights) enjoyed by an adjoining owner. This is no longer the case.

There had always been exceptions: such as where a contact is made with any party who could trigger a claim residential owner was adversely affected; or in cases of under the insurance. That is very diffi cult in this context. A extreme interference or bad conduct by the developer. But fi rm strategic decision would need to be made at the the Court decision in IHRUK II (CHC) v Marcus Alexander outset not to engage with those adjoining owners who Heaney turned this upside down sending shockwaves might have a claim. Is this really practical? There may need throughout the development community in and to be some engagement through the planning process or Wales, destabilising commercial development – including to comply with party wall requirements. Also, what if they hotel projects. approach you? Moreover, even if these issues can be addressed you may fi nd it diffi cult proving to a funder, an In its decision, the Court put a restraining order on an occupier or a purchaser that the insurance conditions have equal footing with monetary compensation. The been complied with and that your insurance policy repercussions are seismic. The risk of a restraining order remains extant. sterilises development unless and until a commercial settlement can be reached with all affected adjoining Extinguishing private rights owners. At the same time, the potential mischief of a Others have sought to approach and encourage local restraining order increases the fi nancial expectations of authorities to use their statutory powers to extinguish such adjoining owners. private rights under section 237 of the Town and Country Planning Act 1990. Instead the private rights are converted Not only does this delay start on site, but this cascades into into a claim for compensation ascertained on a similar basis the developer’s fi nancing arrangements and agreements to compulsory purchase. As with all statutory powers there with occupiers. Both funders and occupiers are likely to are strict requirements attached to their use. Is exercise of refuse to be committed unless and until this risk has been such powers required in the public interest and removed. Planning Permissions will have a requirement for proportionate to the interference to rights that would result? development to commence within a specifi ed period. Sometimes, particularly where there has been a signifi cant The requirements are easier to satisfy where the planning change of use this could be a relatively short period. It may authority retains an interest in the development land not be realistic to conclude all necessary settlement (e.g. through a reversionary freehold) or, at some time in the agreements within that timeframe. past, had acquired the land for the purposes of development. Where that is not so, the procedure will be Insurance as a solution? more involved. The local planning authority would need to Some have suggested insurance as a solution to this acquire the land and appropriate it for development conundrum. A diffi culty here is satisfying the insurers’ purposes in accordance with the local planning authority’s conditions. One common stipulation of insurers is that no statutory powers. Frequently that interest is then transferred back to the developer albeit as a benign long lease.

6 | UK DEVELOPMENT ROUND UP HOSPITALITY MATTERS Even with suitable security from the developer for any How does it work? liabilities to the local authority, anecdotally, many local The Mayoral CIL is levied on increases in fl oor space where authorities remain reluctant to use or to be seen to be new development results in a net increase of 500 square using these powers. The City of London is a notable metres or more in fl oor space. exception and we have used section 237 with other provincial local authorities. This procedure itself is not Liability for CIL is calculated at the date of the planning without risks. It is a highly technical arrangement, meaning permission. Outline applications are liable for CIL on the each stage of the process may be subject to scrutiny and date that the last of the reserved matters is approved, even challenge. Even where it is used successfully, unless and if the outline application was granted prior to CIL coming until a formal compensation agreement has been into force. Payment is due prior to commencement concluded, or an award issued it may be diffi cult proving to of development. funders, occupiers and purchasers that the rights in question have been completely expunged. For more information on how the Mayoral CIL is calculated, availability of discounts and reliefs and the interaction with section 106 planning obligations, see our law-now article James Miller at: tiny.cc/lawnow-mcil. Partner T +44 (0)20 7367 2442 What should hotel developers be doing to protect E [email protected] themselves? If developers have outline planning permissions with London update: the new Mayoral reserved matters approvals outstanding, it may be fi nancially worthwhile submitting those reserved matters Community Infrastructure Levy applications now, before the new CIL charging schedule takes effect, to avoid the extra CIL charge. Developers at an The Crossrail rail project is under construction and due to earlier stage in the process will need to factor the Mayoral open in 2017. Crossrail is funded part by Central CIL into their models and in some cases it may make a Government and part by the Mayor of London via levies on difference to the viability of the project. new development in London, including hotels. On 1 April 2012, a new Mayoral Community Infrastructure Levy Kathryn Jones Associate (Mayoral CIL) will come into force. T +44 (0)20 7367 3148 E [email protected] What is the Mayoral CIL? A Community Infrastructure Levy (CIL) is a levy that local authorities (including the Mayor) can charge against new development, to fund local infrastructure projects. Although the legislation for CIL was introduced in 2008, authorities can only charge CIL when their charging schedule has been examined and approved by an independent inspector.

7 Valid termination of a hotel development agreement?

Recently the English Courts were asked to decide whether The Court decided that a party who was in breach could a party who was in breach of obligations could terminate a not terminate the agreement, upholding a long standing contract. In the case of Extra MSA Services Cobham v Accor legal principle that no man can take advantage of his own the contract in question was an agreement for lease of a wrong. Incidentally the Court was not asked to determine hotel which included development obligations. whether Extra Services was in breach of the agreement.

Accor had entered into an agreement for lease for a 85 This decision will be a welcome relief to operators who sign bedroom hotel at the new Cobham motorway services on up to a conditional agreement and factor the hotel into its the M25, currently in the process of construction. The future business plan and forgo pursing alternative pipeline agreement for lease was conditional on a number of projects. Any attempts by a developer to terminate such an consents being obtained, including various highways and agreement (for example if the developer received a better traffi c consents, and contained agreed termination offer from a competitor) will need to be carefully analysed provisions. It was Extra Service’s obligation to obtain the to ascertain whether the developer has a legitimate right consents. Some three years later, Extra Services sought to to terminate. terminate the agreement for lease. Accor argued that it Danielle Drummond-Brassington could not do so as it was in breach of its obligations under Associate the lease. T +44 (0)20 7367 2768 E [email protected] This agreement was particularly important to Accor who were keen to secure the hotel site and had factored into its business plan and placed this development, along with three others, at the core of its strategy.

8 | UK DEVELOPMENT ROUND UP HOSPITALITY MATTERS Upcoming events

International Hotel Investment Forum 2012 Berlin, 5-7 March 2012

Hotel Operating Agreement, a Henry Stewart Conference London, 21 March 2012 (CMS discount on request)

Hotel Investment Conference South Asia 2012 Mumbai, 3-4 April 2012

Hospitality Investment World 2012 Jakarta, 17-19 April 2012

China Hotel Investment Conference 2012 Shanghai, 18-20 April 2012

Arabian Hotel Investment Conference 2012 Dubai, 30 April-2 May 2012

Hotel Opportunities Latin America Miami, 8-10 May 2012

International Hotel Investment Forum Asia Pacifi c Seoul, 17-18 May 2012

CMS Hotel & Leisure Sector Group Quiz 2012 London, 24 May 2012

NYU International Hospitality Industry Investment Conference New York, 3-5 June 2012

REITWeekL NAREIT’s Investor Forum New York, 12-14 June 2012

Hotel Investment Conference Europe 2012 (Hot.E) London, September 2012

Hotel Owners Conference 2012 London, September/October 2012 (invitation only)

Expo Real 2011 Munich, 8-10 October 2012

Hotel Investment Conference Asia Pacifi c (HICAP) Hong Kong, 10-12 October 2012

Russia & CIS Hotel Investment Conference 2012 Moscow, October 2012

International Hotel Conference 2012 Rome, October 2012

99 Environmental matters affecting Europe: refl ecting on 2011 and further changes ahead

2011 presented a number of legal developments which have direct and indirect effect on the hotels sector, particularly operational costs in the short term and asset value in the long term.

We outline the three key areas: low carbon drivers, EC proposals resource effi ciency measures and energy effi ciency related In March 2011 the European Commission published to buildings and products with reference to articles we proposals for transition to a low carbon economy within have posted over the last 12 months. This summary the EU. Energy effi ciency is the crux of the transition. The provides a fl avour of the initiatives affecting the hotels proposals are working their way through the various parts sector but most are simply a signal of the level of change to of European Government and may be the catalyst for come. More should be expected this year. For further further legislative measures. Proposals include focused information please telephone or email one of the investment in building effi ciency, mandatory regular energy named contacts. audits for large companies, voluntary agreements with industry and the adoption of new ecodesign and energy labelling measures. See further: tiny.cc/lawnow-ecp Low carbon developments UK CRC Energy Effi ciency Scherme Durban platform Most of the hotels sector in the UK will have been There are a number of international measures aimed at impacted by the mandatory CRC Energy Effi ciency Scheme reducing greenhouse gases including carbon dioxide. In (CRC) to some extent. Introduced in April 2010, changes December 2012 the United Nations Framework Convention were implemented last year prior to public dialogue on on Climate Change conference in Durban culminated in simplifi cation proposals. Consultation of the draft agreement to extend the existing agreement (the Kyoto legislation implementing the further simplifi cation Protocol) and for countries to work together to create a proposals is expected early this year. A reminder of the formal legally binding agreement in respect of emissions simplifi cation proposals which are to be implemented into reductions. For global organisations this may mean a draft legislation and shall be the subject of consultation trickling of further measures in previously untouched shortly is here: tiny.cc/lawnow-crc1 territorities increasing costs but potentially incentivising effi ciencies. Details of the Durban platform are available here: tiny.cc/lawnow-dc

10 | ENVIRONMENTAL MATTERS AFFECTING EUROPE HOSPITALITY MATTERS Buildings and energy effi ciency Resource effi ciency measures

2011 saw the Recast of the Energy Performance of In September 2011 the European Commission published a Buildings Directive, modifi ed so that the measures on roadmap on resource effi ciency. For the hotels sector, the energy effi ciency would be more fully implemented in proposals for food, water and buildings are important the EU. considerations for strategic planning. For example one proposal is that “By 2020... all new buildings will be nearly One of the most important changes brought is the zero-energy and highly material effi cient, and policies for introduction of the concept of ‘cost–optimal level’, which is renovating the existing building stock will be in place so akin to life-cycle costing and shall increasingly need to be that it is cost-effi ciently refurbished at a rate of 2% factored into building developments. The idea that per year...” environment related issues are in reality economic issues (identifying exposures or gains thereby impacting on asset A summary of the proposals is available here: value) has been fl oated for some time. Due to mandatory tiny.cc/lawnow-rem instruments the link is becoming increasingly tangible and awareness of these changes is crucial. tiny.cc/lawnow-eure tiny.cc/lawnow-irp

Paul Sheridan Partner T +44 (0)20 7367 2186 E [email protected]

Olivia Quaid Associate T +44 (0)20 7367 2055 E [email protected]

11 UK employment law issues

UK Employment law reforms Olympic hurdles for employers to clear

The UK Government has announced extensive proposals The 2012 Olympic and Paralympic Games raise various for radical reform to the domestic employment law system. potential concerns for employers. In advance of the Games, From 6 April 2012, the qualifying period for the right to businesses will need to manage staff expectations in claim unfair dismissal will be doubled to two years. Other relation to both attending the events and watching them key proposals being considered include: during working hours and/or on work equipment. For businesses based in the vicinity of the various Olympic/ — reforming and streamlining the Employment Tribunal Paralympic venues, there may also be the predicted travel system - introducing fees for anyone wishing to bring disruption to contend with. an employment tribunal claim, placing a greater emphasis on alternative dispute resolution and the Employers should consider how any fl exible working and introduction of a ‘rapid resolution scheme’ for more absence management policies and procedures might straightforward claims operate in relation to these issues. To ensure consistent — streamlining the existing fair dismissal process, treatment of staff and so avoid exposure to any allegations including a system of ‘protected conversations’ to allow of favouritism and/or discrimination, employers may be employers to raise openly issues such as poor well-advised to implement new, clear policies to formalise performance without fear that such discussions will be and communicate their intended approach. We used against them if relations break down recommend that employers obtain bespoke legal advice but the Advisory, Conciliation and Arbitration Service has — reviewing and simplifying the current TUPE Regulations published general guidance, which is available here: and the rules governing collective redundancy www.acas.org.uk/olympics consultation to provide businesses with greater fl exibility.

Consultation is underway and legislation dealing with some Sarah Ozanne or all of the issues is expected during 2012. The stated aim Partner T +44 (0)20 7367 2650 of the proposals is to protect employees whilst encouraging E [email protected] businesses to create jobs. However, there remains a risk that the more employer-friendly aspects of the proposals may be diluted in any legislation that is eventually passed. See further: http://tiny.cc/lawnow-elr Tom Cloke Associate T +44 (0)20 7367 3150 E [email protected]

12 | UK EMPLOYMENT LAW ISSUES HOSPITALITY MATTERS Hotel hot topics

Please see below a summary round up of current legal issues that we are seeing affecting the hotels sector. Further information on these issues can be found at our Law-Now website through the hyperlinks set out below or please do not hesitate to contact the team members set out below.

The Business Premises Renovation incident. The regulations apply to all employers as well as those in control of premises where an incident occurs and is Allowance therefore particularly relevant to the hospitality sector. tiny.cc/lawnow-riddor Draft regulations to extend and amend the business premises renovation allowance (BPRA) for properties in disadvantaged Contact areas was published on 6 December 2011. BPRA is a scheme Jan Burgess - Partner, Health & Safety to incentivise businesses to bring derelict or unused properties T +44 (0)20 7367 3539 E [email protected] back into business use. The scheme broadly allows an initial allowance equal to 100% of the qualifying expenditure incurred in the fi rst year and, to the extent that this allowance Stripping red tape from health and is not claimed, writing down allowances can be claimed at the rate of 25% per annum on a straight line basis. The draft safety - Lofstedt Review regulations extend the BPRA scheme for fi ve years until April 2017. In addition, various amendments have been made to A consultation on the abolition of more than half of the the scheme to ensure compliance with EU State aid rules. UK’s health and safety rules has been launched. An independent review by Professor Lofstedt looked at the tiny.cc/lawnow-bpra scope for “reducing the burden of health and safety regulation on business” without hindering progress in Contact improving health and safety outcomes. The review Sam Dames - Partner, Tax concluded that the UK regime is largely fi t-for-purpose but T +44 (0)20 7367 2470 E [email protected] made several recommendations aimed at cutting down on Harpreet Chatha - Associate, Tax needless bureaucracy, including the removal of certain, T +44 (0)20 7367 2402 E [email protected] unnecessary or out-dated regulations and giving the Health and Safety Executive responsibility to direct the local authorities who deal with low-risk environments. Changes to RIDDOR to come into effect Specifi c proposals are yet to be announced. But this is certainly an area worth watching for the hospitality sector, From 6 April 2012, changes to reporting requirements under as the Government plans to, as the Prime Minister said, the Reporting of Injuries, Diseases and Dangerous Occurrences “take the fear out of the health and safety monster”. Regulations 1995 (RIDDOR Regulations) are expected to come tiny.cc/lawnow-hsrt into effect. Currently employers must report ‘over-three-day’ injuries to the Health and Safety Executive; however the Contact threshold is set to change so that only ‘over-seven-day’ injuries Jan Burgess - Partner, Health & Safety need to be reported. Furthermore the time limit to report such T +44 (0)20 7367 3539 E [email protected] an injury will increase from 10 to 15 days from the date of the

13 Recent transactions and credentials

Galaxy Pub Portfolio Travelodge Thompson Belgravia

Disposal of the Galaxy pubs estate M&G/PruPIM acquired the Management agreement and to Scottish & Newcastle Pub Travelodge Marylebone re-development of Thompson Company, a subsidiary of Heineken Belgravia Hotel

Value £410 million Value £15 million Value not disclosed

CMS acted for West Register as CMS acted for PruPIM CMS acted for Harilela Hotels seller as buyer as owner

Scotsman Hotel Group CitizenM Hotel Verta

Appointment of administrators Development and fi nancing of Appointment of administrators and sale of hotel portfolio, three London hotel projects at and sale of the fi ve star hotel to including The Scotsman Hotel Bankside, St Pauls and Tower Hill a private buyer and Hotel de la Trémoille, Paris

Value confi dential Value not disclosed Value confi dential

CMS acted for Bank of CMS acted for CitizenM as CMS acted for Bank of plc as lender and developer, owner and Scotland plc as lender and KPMG as administrators operator KPMG as administrators

West Register Mergermarket European leisure M&A deals 2010/11

Lease of The Black Boy Inn, Banbury, and The Carnarvon Arms, Rank House No. of deals Newbury, to Marco Pierre White 1CMS 27

2DLA Piper 17 Value confi dential 3Clifford Chance 16 CMS acted for West Register as owner and landlord 4Freshfi elds Bruckhaus Deringer 16

5Linklaters 15

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