POSH policy and training requirements for Indian employers

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 places the obligation on the employer, not on the complainant. In practice that means four things: constitute an Internal Committee by written order, have and publicise a policy, run awareness programmes at regular intervals, and give the Committee the facilities and support it needs to conduct an inquiry — then report annually.

This page covers the policy and the training. For the Act itself — full form, applicability thresholds, how the Internal Committee is composed, complaint timelines and penalties — see our POSH Act 2013 explainer.

A policy that only states the organisation’s disapproval of harassment is not a POSH policy. The document has to be usable by someone who is deciding whether to come forward, which means it must answer their practical questions without them having to ask anyone.

• A definition of sexual harassment consistent with the Act, with examples that make it concrete rather than abstract.
• The scope of “workplace” as it applies to you — offices, client sites, transport provided by the employer, off-site events, and how you treat remote and hybrid work.
• The Internal Committee: who sits on it, including the external member, and how to reach them. Names and contact details, not just a job title.
• How to make a complaint — to whom, in what form, and what happens next.
• The inquiry process and its timelines, so nobody has to guess how long they are waiting.
• Confidentiality obligations, and who is bound by them.
• Protection against retaliation for complainants and witnesses.
• Consequences of a finding, and the treatment of a complaint found to be malicious.
• The annual reporting obligation and who owns it internally.

Two practical points. A policy nobody can find is functionally absent, so where it lives matters as much as what it says. And if you operate from more than one location, the Committee details in the policy have to be right for each of them — the Act contemplates constitution across applicable offices and administrative units, and a single head-office committee named in a policy used everywhere is a common mismatch.

“POSH training” is used to describe two different obligations, and organisations frequently do one and assume they have done both.

Employee awareness programmes

The employer duties include organising awareness programmes for employees at regular intervals. The purpose is that people know the policy exists, understand what conduct it covers, and know how to raise a complaint without having to ask around first. Adding POSH to induction is what keeps new joiners covered between annual sessions.

Internal Committee capability

Separately, the Rules contemplate orientation and capacity-building for Committee members. This is a different subject entirely: inquiry procedure, handling evidence, the principles of natural justice, and confidentiality. It matters because a committee that has never been trained on procedure is where sound cases tend to come apart — not on the facts, but on how the inquiry was conducted.

Committee membership changes. When it does, the new member needs the training, and the policy and displayed notices need updating with their details. That refresh is one of the most commonly missed steps in the whole framework.

Non-compliance carries fines and, on repetition, risk to licences and registrations. That is the part usually quoted, and it is the least interesting part.

• It decides whether someone comes forward at all. A visible policy and a committee people can name is the difference between a complaint being raised internally and being raised somewhere you cannot resolve it.
• It is what an inquiry is judged on. Process failures — no documented procedure, no trained committee, no confidentiality controls — are what turn a defensible outcome into a challengeable one.
• It is increasingly diligenced. Investors, enterprise customers and acquirers ask for the POSH framework and the annual returns. “We have a policy” does not survive the follow-up question.
• It is a signal to employees. A framework that is current and communicated says something about the organisation that a filed-and-forgotten document does not.

The pattern is consistent, and it is rarely the absence of a policy. It is the distance between the document and the practice.

• A committee constituted years ago, with members who have since left.
• No external member, or one appointed on paper who has never participated.
• A single committee where multiple locations require their own.
• A policy that exists but is not findable, and notices that are not displayed.
• Awareness sessions that happened but were never recorded, so they cannot be evidenced.
• Committee members who have had awareness training but no inquiry training.
• The annual report treated as a formality, or missed entirely.

Most of these are invisible from the inside, because the documents all exist. They become visible the moment somebody asks to see the evidence for each one.