POSH Policy & IC Charter

Legislation checked · 26 June 2026 Not yet advocate-reviewed Execution steps verified

Drafted by:: Lekha editorial team
Version:: v0.1
Last checked against current law:: 15 May 2026
Next scheduled review:: 15 November 2026

Statutory sources (6)

Shops and Establishments ActOfficial statuteofficial source
Industrial Employment (Standing Orders) Act, 1946Official statuteofficial source
Indian Contract Act, 1872Official statuteofficial source
Copyright Act, 1957Official statuteofficial source
Patents Act, 1970Official statuteofficial source
Industrial Disputes Act, 1947Official statuteofficial source

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POSH ICC Constitution (short — committee only) ~6 pages · Published · overlapping scope — check which one fits

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Fill every [BRACKETED PLACEHOLDER] — IC member names, designations and the complaint email must be real before adoption.
Adopt the policy formally — board resolution (companies) or a signed management decision; record the effective date.
Constitute the Internal Committee in writing under s.4, POSH Act 2013 — mandatory at 10+ employees; Presiding Officer must be a senior woman employee, with an external NGO/expert member.
Display the policy and IC composition conspicuously at every workplace and on your intranet/notice boards (s.19(b)).
Run awareness and orientation programmes for employees and IC members (s.19(c) read with the POSH Rules, 2013).
File the IC annual report with the District Officer each calendar year (s.21 + Rule 14) and include the POSH compliance statement in the Directors' Report (Companies Act s.134, Rule 8(5)(x)).
Retain inquiry records and annual reports — non-compliance attracts fines up to ₹50,000 (first offence) and higher for repeats.

Generate a POSH Policy & IC Charter for India, free. Complete POSH policy plus Internal Committee (IC) constitution under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 — definitions, complaint procedure, inquiry process, penalties, and return format. Already have a policy and only need to constitute the committee? Use the short ICC Constitution instead. Fill a guided online form and download as PDF or DOCX — no signup, no watermark, no cost.

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Organisation details

Organisation / company name *

Registered office address *

Policy effective date *

Approximate employee count

Internal Committee (IC) constitution

Presiding Officer name *

Presiding Officer designation

IC Member 1 name

IC Member 1 designation

IC Member 2 name

IC Member 2 designation

External / NGO member name

External member NGO / organisation

Nodal officer name

POSH complaint email

4 required fields left.

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POLICY ON PREVENTION, PROHIBITION AND REDRESSAL OF SEXUAL HARASSMENT AT WORKPLACE

(POSH Policy) — As per the POSH Act, 2013

Effective Date: [Effective Date]
Applies to: All employees, contract staff, interns, visitors, and third parties at all workplaces of
POSH Complaint Email

1. Preamble and Commitment

("Company") is committed to providing a safe, respectful, and harassment-free workplace for all employees, irrespective of gender, position, or tenure. The Company has zero tolerance for sexual harassment in any form. This Policy is enacted in compliance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("POSH Act") and the Rules thereunder.

2. Scope

This Policy applies to all: (a) permanent employees, temporary employees, trainees, interns, and consultants; (b) third parties including vendors, clients, visitors, and contractors; at all workplaces including offices, client sites, travel, outstation assignments, company events, and virtual/online platforms.

3. Definition of Sexual Harassment

Under the POSH Act, Sexual Harassment includes any unwelcome act or behaviour (whether directly or by implication) such as: (a) physical contact and advances; (b) a demand or request for sexual favours; (c) making sexually coloured remarks; (d) showing pornography; (e) any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature. It also includes implied or explicit: (i) promise of preferential treatment in employment; (ii) threat of detrimental treatment; (iii) threat about present or future employment status; (iv) interference with work or creation of an intimidating, hostile, or offensive work environment; (v) humiliating treatment likely to affect health or safety.

4. Internal Committee (IC) Constitution

In accordance with Section 4 of the POSH Act, the Company has constituted the Internal Committee (IC) as follows:

Name	Designation / Organisation	Role in IC
		Presiding Officer
		Member
		Member
		External Member (s.4(2)(d))

5. Complaint Procedure

An aggrieved woman may file a written complaint with the IC within 3 months of the incident (extendable by another 3 months for exceptional reasons). The complaint must be addressed to the Presiding Officer at or delivered to (Nodal Officer). If the aggrieved woman is unable to file a written complaint due to physical or mental incapacity or otherwise, the Presiding Officer may take cognisance of the complaint on her behalf.

6. Conciliation

Before initiating an inquiry, the IC may, at the request of the aggrieved woman, take steps to settle the matter through Conciliation between the parties. No monetary settlement shall be made as the basis of conciliation. If conciliation is reached, the IC shall record and forward the settlement to the employer and the aggrieved woman and the respondent shall comply with the settlement.

7. Inquiry Process

Where conciliation is not sought or fails, the IC shall proceed with an inquiry in accordance with the provisions of the POSH Act and the Principles of Natural Justice: (a) both parties shall be given an opportunity to be heard; (b) the inquiry shall be completed within 90 days; (c) the IC shall have the power to call witnesses and examine documents; (d) the proceedings shall be kept confidential; (e) no legal practitioner shall represent either party during inquiry proceedings.

8. Interim Relief

Pending the inquiry, the IC may recommend to the employer: (a) transfer of the aggrieved woman or respondent; (b) grant leave to the aggrieved woman up to 3 months; (c) restraining the respondent from reporting on the work performance of the aggrieved woman.

9. Penalties for Sexual Harassment

On completion of the inquiry, if the allegation is proved: (a) the IC shall recommend termination of employment, demotion, or other disciplinary action as per the company's service rules; (b) the IC may recommend deduction from salary / compensation of the respondent to be paid to the aggrieved woman; (c) if the respondent is a third party, the Company shall take appropriate action including cancellation of vendor/contract arrangement.

10. Protection against Retaliation

No employee shall be penalised, retaliated against, or suffer any adverse consequence in employment for making a complaint in good faith, cooperating in an inquiry, or exercising any right under this Policy or the POSH Act. Any retaliatory action is itself a disciplinary offence.

11. False Complaints

If the IC concludes that the allegation is false or malicious, it may recommend disciplinary action against the complainant. However, the failure to prove a complaint shall not constitute a false complaint per se.

12. Confidentiality

The identity of the aggrieved woman, the respondent, witnesses, and the contents of the complaint, inquiry, and final report shall be kept strictly confidential. Breach of confidentiality is a disciplinary offence and may also attract penalties under the POSH Act.

13. Awareness and Training

The Company shall organise awareness programmes and workshops on sexual harassment at the workplace at regular intervals (minimum once per year) for all employees. The IC members shall undergo periodic sensitisation training.

14. Annual Report

The IC shall prepare an Annual Report to be submitted to the employer and the District Officer, containing: number of complaints received, disposed of, pending, and action taken.

This Policy has been adopted by and shall be effective from [Effective Date]. All employees are required to acknowledge and comply with this Policy.

Authorised Signatory

Presiding Officer, IC

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Acts this document touches

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Shops and Establishments Act Industrial Employment (Standing Orders) Act, 1946 Indian Contract Act, 1872 Copyright Act, 1957 Patents Act, 1970 Industrial Disputes Act, 1947

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