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Free policy template · Word

POSH Policy

A POSH policy sets out the company's commitment and procedure under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 — what sexual harassment means, the Internal Committee required where there are 10+ employees, how to file a complaint, conciliation and inquiry, confidentiality, interim relief and awareness obligations.

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[Highlighted] = fill in
[Company Logo][Company Name]

POLICY ON PREVENTION OF SEXUAL HARASSMENT (POSH)

Policy No.:
[Reference Number]
Version:
[Version Number]
Effective Date:
[Date]
Policy Owner:
Human Resources / Internal Committee

1. Purpose

[Company Name] is committed to a workplace free of sexual harassment. This policy is framed under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and its Rules, to prevent sexual harassment and provide a fair redressal mechanism.

2. Scope

It applies to all employees, interns, trainees, consultants, contract staff and visitors at all locations of the company, including [Work Location]. 'Workplace' includes offices, sites, company transport, places visited during work, and work-related online spaces. As company policy, [the protections are extended to employees of all genders].

3. Definitions

Sexual harassment includes any unwelcome act or behaviour, 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. Implied promises of preferential treatment, threats about employment, interference with work, or creating a hostile environment connected with such conduct may also amount to sexual harassment.

4. Policy

  1. The company has zero tolerance for sexual harassment.
  2. An Internal Committee (IC) is constituted at [each office with 10 or more employees], as below.
  3. Complaints are handled with confidentiality as required by the Act.
  4. No complainant or witness will be victimised or retaliated against.
  5. The company will provide necessary facilities to the IC and assist in securing attendance of the respondent and witnesses.
RoleNameDesignationContact
Presiding Officer[Name][Designation][Phone / Email]
Member[Name][Designation][Phone / Email]
Member[Name][Designation][Phone / Email]
External Member[Name][Organisation][Phone / Email]

5. Procedure

  1. The aggrieved woman may submit a written complaint to the IC within the time limit prescribed by the Act. The IC will assist if she is unable to write it.
  2. Before inquiry, at the request of the complainant, the IC may attempt conciliation; no monetary settlement can be the basis of conciliation.
  3. If there is no conciliation, the IC conducts an inquiry following the principles of natural justice: the respondent receives a copy of the complaint and both parties may present their case and witnesses.
  4. During the inquiry, on the complainant's written request, the IC may recommend interim relief such as transfer or leave.
  5. The IC completes the inquiry and submits its report with recommendations within the timelines prescribed by the Act; the employer acts on the recommendations within the prescribed period.
  6. Either party may appeal as provided under the Act.

6. Responsibilities

  • Employer: constitute the IC, display this policy and IC details, conduct awareness programmes and orientation for IC members, and include required information in the annual report.
  • IC: receive complaints, conduct inquiries fairly and prepare the annual report.
  • Managers: escalate concerns and support the process.
  • Employees: maintain respectful conduct and cooperate with inquiries.

7. Non-compliance

Where sexual harassment is proved, action will be taken as per the IC's recommendations and service rules, which may include written apology, warning, withholding of promotion or increment, counselling, community service or termination. Malicious complaints or false evidence, once established through inquiry, may also lead to action; mere inability to prove a complaint is not malicious.

8. Review & Approval

HR and the IC will review this policy annually and on any change in law. The IC is reconstituted on completion of members' tenure as per the Act.

Approved by
[Authorised Signatory]
[Designation]
Date: [Date]
Acknowledged by
[Employee Name]
Employee ID: [Employee ID]

What this template includes

  • Policy statement of zero tolerance
  • Definitions of sexual harassment and workplace as per the Act
  • Internal Committee composition — Presiding Officer, members and external member
  • Complaint filing, conciliation and inquiry steps
  • Interim relief and confidentiality
  • Awareness, display and annual reporting obligations

When to use it

  • Your company has or will soon have 10 or more employees
  • Constituting or reconstituting the Internal Committee
  • Clients or auditors ask for your POSH policy
  • Running annual POSH awareness training

How to customise this template

  1. 1Insert the names and contacts of Internal Committee members
  2. 2Add all office locations covered
  3. 3State whether the policy is extended to all genders (as company policy)
  4. 4Insert the display locations and training calendar
  5. 5Check timelines and procedures against the Act and Rules before publishing

HR tips

  • Display IC member names and contacts at every location
  • Train IC members on conducting inquiries, not just employees on awareness
  • Keep inquiry records strictly confidential
  • Make sure the external member meets the Act's requirements

The POSH Act 2013 and its Rules prescribe the Internal Committee's composition, timelines and procedure. This template is a starting point; verify every step against the Act, Rules and any state requirements with a legal adviser.

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Frequently asked questions

Is a POSH policy mandatory?+

Employers with 10 or more employees must constitute an Internal Committee under the POSH Act 2013, and the Act requires employers to formulate and widely disseminate a policy. Smaller workplaces are covered by the Local Committee.

Who should be on the Internal Committee?+

The Act requires a Presiding Officer who is a senior woman employee, at least two employee members, and one external member from an NGO or person familiar with the issues, with at least half the members being women.

Can men file complaints under the POSH policy?+

The Act protects women. Many companies extend their internal policy to all genders as a matter of company policy, while handling women's complaints in accordance with the Act.

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