Lasors states:
Carriage of Passengers
Pilots not operating in accordance with JAR-OPS
or EU-OPS’ are required to meet recent experience
criteria to carry passengers. A pilot shall not operate an
aeroplane or helicopter carrying passengers as pilot-incommand
or co-pilot unless that pilot has carried out at
least three take-offs and three landings as pilot flying
(sole manipulator of the controls) in an aeroplane or
helicopter of the same type/class or flight simulator of the
aeroplane type/class or helicopter type to be used in the
preceding 90 days. If the flight is to be carried out in an
aeroplane at night, one of these take-offs and landings
must have been at night, unless a valid instrument rating is
held. If the flight is to be carried out in a helicopter at night,
3 take-offs and landings must have been at night, unless a
valid instrument rating (helicopters) is held.
A pilot who has not met the experience criteria above
will be required to complete the above requirements
either as Pilot-in-Command of aeroplanes/helicopters as
appropriate or with a flight instructor, providing that the
instructor does not influence the controls at any time. The
carriage of a safety pilot is not permitted to satisfy this
requirement.
This would seem to me to be fairly conclusive as a Safety Pilot is not permitted. So it's either on your own (ie PIC - manipulating the controls while someone else is 'acting PIC' is not permitted) or with an instructor. I think they use the 'sole manipulator of controls' statement simply to account for the fact that if using an instructor then you won't be P1. Hope this helps clear any confusion (and please don't take my word as gospel, it's just my understanding and I'm no more qualified than anyone else on this thread).