Lesbian, bisexual and transgender (“LBT”) women experience gender-based violence both on account of their gender and because of the way their sexual orientation or gender identity challenges patriarchal concepts of gender and gender roles. This double exposure to causes of gender-based violence puts them at particular risk. A recent survey by London’s Metropolitan Police of more than 1100 LBT women found that approximately twice as many had experienced violence or abuse on account of their sexual orientation or gender identity as on all other grounds, despite the fact that nearly half of respondents changed their behaviour or appearance to avoid homophobic or transphobic abuse. This double exposure also means that violence against them can only be addressed effectively by the Convention if the part played by homophobia and transphobia is acknowledged and specific counter-measures identified. However, there is a further reason to acknowledge explicitly violence against LBT women. Regrettably, as the Committee of Ministers has stressed, homophobia and transphobia are widespread in Europe.2 Without specific references in the Convention it remains all too possible that its measures will not be used to combat violence against LBT women. Inclusion of such references would be an effective response to the invitation of the Committee of Ministers to all intergovernmental committees to make proposals to strengthen, in law and in practice, the equal rights and dignity of LGBT persons and to combat discriminatory attitudes against them. This submission therefore recommends that the Convention identify groups of women who are especially vulnerable to violence, including specifically LBT women, and suggests areas where particular measures are required to address violence against them, such as awareness-raising, education, improving confidence by LBT women in law enforcement agencies, increasing the level of incidents reported to the police, and specific training for agencies involved in victim support. It also recommends that the non-discrimination clause of the Convention makes explicit reference to sexual orientation and gender identity.