POSH Policy & Internal Committee — Format (2013 Act)

When is a POSH policy and Internal Committee required?

Every workplace with 10 or more employees must constitute an Internal Committee (IC) under Section 4 of the POSH Act, 2013, and adopt a policy prohibiting sexual harassment. The obligation applies to companies, LLPs, proprietorships and other establishments alike, and covers all women at the workplace, including regular, temporary, contractual employees, trainees, interns and visitors.

Constitution of the Internal Committee

• Presiding Officer — a woman employed at a senior level at the workplace.
• At least two members from among the employees, preferably committed to the cause of women or with legal knowledge or social-work experience.
• One external member from an NGO or association committed to the cause of women, or a person familiar with the issue.
• At least one-half of the total members must be women; members hold office for up to three years.

Complaint and redressal at a glance

A written complaint may be made to the IC within three months of the incident. The IC may attempt conciliation at the complainant’s request (without a monetary settlement), completes any inquiry within 90 days following natural justice, and submits its report within 10 days; the employer acts on the recommendations within 60 days. The identity of the parties is kept confidential, and there is protection against retaliation. The IC files an annual report with the employer and District Officer, and the company includes the required statement in the Board’s Report.

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