POSH Compliance & Internal Committee Setup

How It Works

1. 1

   Assess current compliance status and headcount

   Review the organisation's employee count across all locations, verify whether an ICC already exists and whether it is validly constituted, identify any previous complaints or pending matters, and confirm the applicable District Officer jurisdiction for annual reporting.

2. 2

   Identify and onboard the external ICC member

   Source a qualified external member from an NGO, legal background, or professional network committed to women's welfare, obtain their consent and credentials, and verify that they meet the Act's requirements. The external member must not have any conflict of interest with the employer or the employees.

3. 3

   Draft the ICC constitution order and POSH policy

   Prepare a formal written order from the employer constituting the ICC, naming all members with their tenure period. Draft a comprehensive POSH policy covering definitions aligned with the Act, complaint procedure, inquiry timelines (60 days as prescribed), interim relief provisions, and confidentiality obligations.

4. 4

   Conduct ICC member training

   Deliver a training session for all ICC members covering the Act's provisions, the step-by-step inquiry procedure including natural justice principles, evidence handling, preparation of inquiry reports, and the external member's independent role. This training should be documented with attendance records.

5. 5

   Roll out employee awareness programme

   Conduct a company-wide awareness session for all employees explaining what constitutes sexual harassment under the Act, how to file a complaint, the ICC's role, confidentiality protections, and non-retaliation provisions. Display the POSH policy and ICC member names at all workplaces as required by Section 19 of the Act.

6. 6

   Establish annual compliance calendar

   Set up a recurring compliance calendar covering annual ICC training refreshers, annual report preparation and submission to the District Officer, ICC member tenure tracking and timely reconstitution, and integration of POSH awareness into new employee onboarding and annual policy acknowledgement processes.