LAMBETH/PCN by CEO/ CODE 02 UNLOADING RESTRICTIONS / ATLANTIC ROAD

I am acting on behalf of a driver of one of our fleet vehicles.
He delivers large amounts of food to a restaurant in Atlantic Road.  The loading bays are always full of motorbikes or other vehicles.  There is nowhere to park at all, even after circling back a few times. The vehicles in the bays appear to never be penalised.  Our driver has received 5 other tickets at this location since November 2024.  Can we argue that our driver is being treated unfairly because the loading bays are always full?  I don't understand how to insert a pic of the PCN, but here is the google image -

PCN number LJ36570481
VRN BF72HUO

Thanks for reading!

If they penalised your driver surely they are also monitoring the loading bays.

But you can have a go at discretion on failure to turnover loading spaces.

Our driver spoke to the CEO at the time about the vehicles in the loading bays, but 'apparently' the CEO didn't appear to care. 
I will ask for discretion, but will not mention the conversation with the CEO as I would like to keep it professional. 
Thanks for your reply

A Notice to Owner has been issued, have you received it?

Were informal reps made?

PCN issued 1 Aug.