POSH Policy Format
A POSH policy is a mandatory workplace policy under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, that defines what constitutes sexual harassment, establishes the Internal Committee (IC) responsible for handling complaints, and sets out the complaint, inquiry, and redressal process.
In India, every organisation with 10 or more employees is legally required to constitute an Internal Committee and have a written POSH policy in place; HR is responsible for drafting, communicating, and periodically reviewing this policy, along with conducting mandatory awareness training and filing the annual compliance report.
POSH Policy — sample format
Copy the template below and replace the [bracketed] fields.
1. Purpose and Statement of Commitment
[Company Name] is committed to providing a safe workplace, free from sexual harassment, for all employees. This policy is framed in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("the POSH Act") and applies to all employees, interns, contractors, and visitors at all company locations.
2. Definition of Sexual Harassment
Sexual harassment includes any one or more unwelcome acts or behaviour, whether directly or by implication, such as physical contact and advances, a demand or request for sexual favours, sexually coloured remarks, showing pornography, or any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature, as defined under Section 2(n) of the POSH Act.
3. Internal Committee (IC)
In accordance with Section 4 of the POSH Act, [Company Name] has constituted an Internal Committee at [each location/administrative unit], comprising:
- A Presiding Officer — a senior woman employee
- Not less than two Members from among employees committed to the cause of women or with relevant experience
- One external Member from an NGO or association committed to the cause of women, or familiar with sexual harassment issues
At least half of the IC's total members shall be women. The current IC composition and contact details are published at [location, e.g. "the HR portal/notice board"].
4. Complaint Procedure
An aggrieved employee may submit a written complaint to the IC within 3 months of the incident (extendable by the IC for reasons recorded in writing). The IC will complete its inquiry within 90 days of the complaint and submit its report within 10 days of completing the inquiry, in accordance with the timelines prescribed under the POSH Act.
5. Confidentiality
The identity of the complainant, respondent, and witnesses, along with the details of the complaint and inquiry, shall be kept strictly confidential, as required under Section 16 of the POSH Act.
6. Interim Relief
The IC may recommend interim measures during the pendency of the inquiry, such as transfer of either party or granting leave to the complainant, as permitted under the Act.
7. Action on Findings
Based on the IC's findings, [Company Name] will take appropriate action, which may include disciplinary action up to and including termination, in accordance with the Company's service rules and the POSH Act.
8. Prohibition of Retaliation
Any retaliation against a complainant, respondent, or witness for participating in good faith in a POSH proceeding is strictly prohibited and will itself be treated as misconduct.
9. Awareness and Training
[Company Name] will conduct periodic awareness programs and training on this policy for all employees and IC members.
What to include
- ✓ Statutory definition clause — mirrors Section 2(n) of the POSH Act to ensure the policy's scope matches the law exactly
- ✓ Internal Committee composition clause — specifies Presiding Officer, internal members, and mandatory external member per Section 4
- ✓ Complaint timeline clause — states the 3-month complaint window and 90-day inquiry timeline prescribed under the Act
- ✓ Confidentiality clause — reflects the mandatory confidentiality obligation under Section 16 of the POSH Act
- ✓ Anti-retaliation clause — protects complainants and witnesses from victimisation, reinforcing good-faith reporting
Legal notes (India)
- § Under Section 4 of the POSH Act, 2013, every employer with 10 or more employees (counting all categories — permanent, contract, interns, consultants) must constitute an Internal Committee at each administrative unit/office; workplaces with fewer than 10 employees fall under the jurisdiction of the district-level Local Committee (LC) instead.
- § The POSH Act mandates strict confidentiality of the complaint and inquiry proceedings under Section 16, and companies are also required to include information on the number of POSH complaints received and resolved in their annual Board of Directors' report as mandated under the Companies Act, 2013 read with related rules.
- § Employers are legally required to conduct periodic sexual harassment awareness training/workshops for employees and orientation for IC members, and non-compliance with POSH Act obligations (including failure to constitute an IC) can attract monetary penalties under the Act.
Frequently asked questions
Is a POSH policy mandatory for all Indian companies?
What happens if a company has fewer than 10 employees?
How long does the IC have to complete a POSH inquiry?
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