POSH Policy Generator
Generate a policy on prevention of sexual harassment under the 2013 Act — definitions, the Internal Committee and its composition, complaint timelines, the inquiry, action and the non-retaliation position.
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An Internal Committee is mandatory at ten or more. Below that, complaints go to the district's Local Committee.
Must be a woman employed at a senior level at the workplace. Mandatory at ten or more employees.
At least two, committed to the cause of women or with legal knowledge or social work experience.
Mandatory. From an NGO committed to the cause of women, or a person familiar with issues relating to sexual harassment. The requirement most often missed.
Every administrative unit or office needs committee coverage.
Nothing you type here leaves your browser — the document is built on this page, and there is no server to send it to. Printing gives you the document alone, without the page around it.
Still to fill, shown as [square brackets] below: Company name, Effective date, Presiding Officer, External member
[COMPANY NAME]
POLICY ON PREVENTION OF SEXUAL HARASSMENT AT THE WORKPLACE
Version: 1.0
Effective from: [Effective date]
Owner: [Policy owner]
Applies to: All employees
================================================================
1. PURPOSE AND SCOPE
[Company name] is committed to a workplace free from sexual harassment.
This policy is issued under the Sexual Harassment of Women at Workplace
(Prevention, Prohibition and Redressal) Act, 2013.
It applies to every workplace of the company, including client sites, off-site
meetings, work-related travel, company events and any virtual workspace. It
protects every woman at the workplace, whether she is an employee, on probation,
a contractor, a consultant, an intern, an apprentice, a temporary worker or a
visitor.
2. WHAT SEXUAL HARASSMENT MEANS
Sexual harassment includes any one or more of the following unwelcome acts or
behaviour, whether directly or by implication:
(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.
The following circumstances, among others, also amount to sexual harassment where
they occur in relation to any act or behaviour of sexual harassment: an implied or
explicit promise of preferential treatment; an implied or explicit threat of
detrimental treatment; an implied or explicit threat about present or future
employment status; interference with work or the creation of an intimidating,
offensive or hostile work environment; and humiliating treatment likely to affect
health or safety.
Whether conduct is unwelcome is judged from the perspective of the person
experiencing it, not the intention of the person doing it.
3. THE INTERNAL COMMITTEE
The company has 50 employees and has constituted an Internal Committee as
required by section 4 of the Act.
The Internal Committee is:
Presiding Officer [Presiding Officer — a woman at a senior level]
Members [At least two employee members]
External member [External member from an NGO or familiar with the issues]
At least half the members are women. The external member is mandatory and is drawn
from a non-governmental organisation or association committed to the cause of women,
or is a person familiar with issues relating to sexual harassment. Members hold
office for not more than three years.
4. MAKING A COMPLAINT
A complaint may be made in writing to the Internal Committee,
within three months of the incident, or of the last incident in a series. That
period may be extended by a further three months where the committee is satisfied
that circumstances prevented an earlier complaint.
Where the complainant is unable to make a complaint herself, it may be made on her
behalf by a person specified in the rules, with her written consent.
Assistance in writing the complaint will be provided on request.
5. CONCILIATION
At the complainant's request, and before beginning an inquiry, the committee may
attempt to settle the matter through conciliation. No monetary settlement may be
made the basis of conciliation. Where a settlement is reached it is recorded and
no further inquiry is conducted.
6. INQUIRY
The committee conducts the inquiry in accordance with the Act and the rules, and
in accordance with the principles of natural justice. The respondent is given the
complaint and an opportunity to reply. Both parties may be heard. Neither party may
bring a legal practitioner to represent them.
The inquiry is completed within 90 days. The committee's report is provided to the
employer within 10 days of completion and is made available to both parties.
During the pendency of an inquiry, the committee may recommend interim relief,
including transferring either party, granting the complainant leave of up to three
months in addition to her entitlement, or restraining the respondent from reporting
on the complainant's work.
7. ACTION
The employer will act on the committee's recommendations within 60 days of
receiving the report. Where sexual harassment is proved, action is taken under the
company's service rules, which may include a written apology, a warning, withholding
of promotion or increment, counselling, community service, or termination of
employment. Compensation may be recommended and may be deducted from the
respondent's salary.
Either party may appeal within 90 days of the recommendation.
8. FALSE OR MALICIOUS COMPLAINTS
Where the committee concludes that a complaint was malicious, or that false
evidence was produced, it may recommend action. A complaint that cannot be
substantiated is NOT the same as a false complaint, and no action will be taken
merely because a complaint was not proved.
9. CONFIDENTIALITY
The identity of the complainant, the respondent, the witnesses, the contents of the
complaint, the inquiry proceedings and the recommendations are confidential and
will not be published or disclosed, except as the Act permits. Breach of
confidentiality carries a penalty under the Act.
10. NO RETALIATION
Retaliation of any kind against a complainant, a witness or a committee member is a
serious disciplinary matter, entirely separate from the outcome of the complaint.
11. AWARENESS AND REPORTING
The company displays the penal consequences of sexual harassment and the
composition of the committee at a conspicuous place at each workplace, conducts
awareness programmes for employees and orientation for committee members, and files
the annual report required by the Act with the District Officer.
12. NON-COMPLIANCE BY THE COMPANY
Failure to constitute a committee or to comply with the Act is punishable with a
fine of up to ₹50,000, and a repeat contravention can lead to cancellation of the
company's licence or registration.
REVIEW
This policy is reviewed annually and whenever the law changes. Where anything in
it falls below a statutory entitlement, the statute applies and this policy is to
be read as amended accordingly.
Questions about this policy should be raised with the human resources team at
[Company name].POSH compliance is a statutory obligation with penalties attached, and a committee that is wrongly constituted invalidates the process built on it. Have this reviewed by an adviser before you publish it.
Every employer with ten or more employees must constitute an Internal Committee under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. A policy without a properly constituted committee is not compliance.
The composition is prescribed: a Presiding Officer who is a woman at a senior level, at least two employee members, and — the requirement most often missed — a mandatory external member from an NGO or someone familiar with the issues. At least half the members must be women.
What the Act requires of an employer
Constitute an Internal Committee at every workplace with ten or more employees, and at every administrative unit or office. Display the penal consequences of sexual harassment and the committee's composition at a conspicuous place. Conduct awareness programmes for employees and orientation for committee members.
Provide a safe working environment, assist the complainant if she chooses to file a criminal complaint, treat sexual harassment as misconduct under the service rules, and file an annual report with the District Officer.
Failure to comply is punishable with a fine of up to ₹50,000, and a repeat contravention can lead to cancellation of the company's licence or registration.
The timelines
A complaint must be made within three months of the incident, or of the last incident in a series, extendable by a further three months where the committee is satisfied that circumstances prevented an earlier complaint.
The inquiry must be completed within 90 days. The report goes to the employer within 10 days of completion and is made available to both parties. The employer must act on the recommendations within 60 days. Either party may appeal within 90 days.
Two things a policy should say and often does not
That a complaint which cannot be substantiated is not the same as a false complaint. The Act permits action for a malicious complaint or false evidence — not for a complaint that simply could not be proved, and conflating the two deters genuine complaints.
That retaliation against a complainant, a witness or a committee member is a separate disciplinary matter regardless of the outcome. Without that sentence, a complainant whose complaint is not upheld has no stated protection.
Frequently asked questions
- Is a POSH policy mandatory in India?
- An employer with ten or more employees must constitute an Internal Committee and comply with the Act, which in practice requires a written policy. Below ten employees the obligation to constitute a committee does not apply, but the Act still does — complaints go to the district's Local Committee.
- Who must be on an Internal Committee?
- A Presiding Officer who is a woman employed at a senior level, at least two employee members committed to the cause of women or with legal knowledge or social work experience, and one external member from an NGO or familiar with the issues. At least half the members must be women, and members hold office for no more than three years.
- How long does a POSH inquiry take?
- The inquiry must be completed within 90 days. The committee's report goes to the employer within 10 days of completion, and the employer must act on its recommendations within 60 days.
- What is the penalty for not having a POSH committee?
- A fine of up to ₹50,000. A repeat contravention can lead to a higher penalty and to cancellation of the company's licence or registration.
- Does the POSH Act protect men?
- The Act as drafted protects women at the workplace. Many employers extend equivalent protection to all employees through a gender-neutral anti-harassment policy alongside the statutory POSH policy, which is good practice — but it does not replace the statutory committee and process.
About this tool
Built by the ViniOffice team. Figures and rules last reviewed 22 September 2026 against the statutory reference this team maintains. Indian statutory rates are date-effective and change by notification — confirm against the current one before running payroll or filing. POSH compliance is a statutory obligation with penalties attached, and a committee that is wrongly constituted invalidates the process built on it. Have this reviewed by an adviser before you publish it.
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