POSH Policy Format (Prevention of Sexual Harassment at Workplace)
Adopt a written policy on preventing and redressing sexual harassment at the workplace, with your Internal Committee and the statutory timelines.
What it is
The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 requires every employer to provide a safe workplace and to deal with complaints of sexual harassment. An employer with 10 or more employees must constitute an Internal Committee at each office or administrative unit. A written policy sets out what sexual harassment means, who can complain, how complaints are made and inquired into, interim relief, confidentiality, appeal and the employer's duties.
When it is used
- Every employer with 10 or more employees, including partnerships, LLPs, trusts and societies.
- Smaller employers who want a written policy for complaints that go to the Local Committee of the district.
- Updating an older policy when the Internal Committee is reconstituted.
What the template covers
- Scope, definitions and who is protected
- Constitution of the Internal Committee
- Complaint procedure and conciliation
- Inquiry, interim relief and timelines
- Confidentiality and protection against retaliation
- Action, appeal, awareness programmes and annual report
Details you will need
The generator asks for the following. Fields marked with an asterisk in the form are required; the rest can be left blank and filled in later in Word.
Policy Details
Effective Date; Date Approved by Board / Management (optional); Who the Policy Protects
Employer
Name of the Employer; Type of Entity; Registered / Head Office Address; Offices / Units Covered (optional); Number of Employees (all units); District (for Local Committee / District Officer)
Internal Complaints Committee
Internal Complaints Committee Members: Name, Role on Committee, Gender, Designation / Organisation, Phone / E-mail; Committee Constituted On; E-mail for Complaints
Approval
Appellate Authority (optional); Approved by (Name); Designation
Stamp duty, registration and filing
Under the Act, the Internal Committee is headed by a senior woman employee, has at least two employee members and one external member, and at least half its members are women (Section 4). A complaint is made within three months of the incident, extendable by three months (Section 9); the inquiry is completed within 90 days (Section 11) and the employer acts on the report within 60 days (Section 13). An appeal lies within 90 days (Section 18). The committee files an annual report (Section 21). Failure to constitute the committee or comply can attract a fine of up to ₹50,000 (Section 26).
Generate the POSH Policy (Prevention of Sexual Harassment at Workplace)
Fill in the form and download the draft as a Word file. It is a general template, not legal or professional advice; have it reviewed for your facts before you sign or rely on it.
Need this checked against your facts, or the registration or filing that follows (e.g. PF, ESI, TDS on salary)? Contact SKAG and Associates
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Frequently asked questions
Is a POSH policy mandatory for small businesses?
The duty to prevent harassment applies to every employer. The Internal Committee is mandatory where there are 10 or more employees; complaints from smaller workplaces go to the Local Committee constituted by the District Officer.
Who must be the external member of the Internal Committee?
A person from a non-governmental organisation or association committed to the cause of women, or a person familiar with issues relating to sexual harassment.
Does the policy cover employees of contractors and visitors?
Yes. The Act protects any woman at the workplace, whether employed or not, including contract staff, interns and visitors.
What goes into the annual report?
The number of complaints received and disposed of during the year, cases pending, and the workshops and awareness programmes conducted.
This page gives general information for reference only. Laws, stamp duty rates and filing requirements change and differ between States, so confirm the current position for your case. Related: all document templates · free tax calculators · compliance calendar and guides.