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Understanding PoSH Policy and Documentation: A Guide for Compliance-Ready Workplaces

Understanding PoSH Policy and Documentation: A Guide for Compliance-Ready Workplaces

By NBC Elite – You are a Compliance Partner

Creating a safe, inclusive, and respectful workplace is more than a moral obligation; it’s a legal one. The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (commonly known as the PoSH Act) mandates every organization with 10 or more employees to formulate a formal PoSH policy and maintain comprehensive documentation to address and prevent workplace sexual harassment.

Why is a PoSH Policy Essential?

A well-structured PoSH policy:

  • Ensures legal compliance
  • Communicates zero tolerance towards harassment
  • Builds a respectful and secure work culture
  • Reduces legal liability
  • Encourages employees to speak up with confidence

Core Components of a Strong PoSH Policy

NBC Elite recommends including the following in your workplace PoSH policy:

  1. Objective and Scope

Clearly define the objective of the policy, i.e., prevention, prohibition, and redressal of sexual harassment. Specify that it applies to all employees (including interns, part-timers, and consultants) across all locations.

  1. Definition of Sexual Harassment

Refer to Section 2(n) of the PoSH Act to include:

  • Physical contact and advances
  • Unwelcome sexual advances, demands, or requests
  • Sexually colored remarks
  • Displaying pornography
  • Any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature
  1. Internal Complaints Committee (ICC)

Detail the structure, appointment process, powers, and responsibilities of the ICC. Mention the contact details of ICC members and the confidentiality norms to be followed.

  1. Complaint Procedure

Lay out:

  • How to file a complaint (written, electronic, etc.)
  • Time frame (within 3 months of the incident)
  • Inquiry process and timelines
  • Support during the process
  • Resolution or appeal options
  1. Consequences of Misconduct

Explain the disciplinary actions for those found guilty and the recourse in case of false or malicious complaints (by Section 14 of the Act).

  1. Awareness and Training

Mention the employer’s responsibility to:

  • Conduct regular PoSH awareness workshops
  • Train ICC members
  • Display policy in prominent locations

Documentation Essentials under PoSH

Proper documentation is key to transparency and legal compliance. Here’s what your organization must maintain:

  1. PoSH Policy Document

Approved and circulated across departments, in both physical and digital formats.

  1. ICC Constitution Records

Appointment letters, member details, and term durations should be properly recorded.

  1. Complaint Register (Confidential)

Maintain a secure internal register tracking:

  • Date of complaint
  • Nature of complaint
  • Complainant and respondent (coded to protect identity)
  • ICC proceedings
  • Final action taken
  1. Training Records

Keep records of:

  • Employee awareness sessions
  • ICC training programs
  • External expert sessions
  1. Annual Report to District Officer

Submit an annual PoSH compliance report, including:

  • Number of complaints received/disposed
  • Pending cases
  • Workshops conducted

How NBC Elite Can Help

At NBC Elite, we simplify PoSH compliance with:

✅ Customized PoSH Policy Drafting
✅ ICC Setup & Member Training
✅ Employee Awareness Workshops
✅ Documentation Templates & Audit Support
✅ Digital PoSH Complaint Portals

Final Thought

A robust PoSH policy, backed by proper documentation, is the cornerstone of a safe workplace. It not only ensures compliance but also reflects your organization’s commitment to dignity and equality.

Let us build workplaces where everyone feels respected and secure.

Want to check your organization’s PoSH compliance status?
Contact NBC Elite today for a free policy review or documentation audit.