The colony of 15 Gentoo birds is housed in a "basement" at Sea Life London Aquarium, according to Freedom for Animals.
The group, which has launched a petition calling for their release into a sanctuary, claim the enclosure offers just seven feet of diving depth. This is a fraction of the 600ft the birds can dive to in the wild, they said.
Dr Andrew Kelly, director of Freedom for Animals, added: "Sea Life London Aquarium has a tiny basement in which a colony of penguins Gentoo spend their lives.
"Its parent company, Merlin Entertainments, owns a number of tourist attractions including London Dungeon.
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