POSH questions, answered plainly

POSH stands for Prevention of Sexual Harassment. It is the everyday name for the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, and for the compliance every employer with 10 or more employees must put in place under it.

Any unwelcome conduct of a sexual nature, direct or implied: physical contact and advances, a demand or request for sexual favors, sexually colored remarks, showing pornography, or any other unwelcome physical, verbal or non-verbal conduct of a sexual nature. Linked promises of preferential treatment, threats about her job or its future, interference with her work, an intimidating or hostile work environment, or humiliating treatment likely to affect her health or safety can also amount to sexual harassment. Source: Sections 2(n) and 3(2).

No — the Act protects women: an “aggrieved woman” of any age, whether employed or not (Section 2(a)). Many employers also adopt a gender-neutral anti-harassment policy so that everyone is protected under company rules, but complaints under the POSH Act itself are brought by women.

Far more than your office. It covers private-sector organizations of every kind, and any place an employee visits arising out of or during the course of employment — including transport the employer provides for that journey (Section 2(o)). Client sites, business travel, off-sites and work events can all fall within it.

POSH is India’s statutory framework protecting women employees from sexual harassment at the workplace. PSEA — Protection from Sexual Exploitation and Abuse — is the broader, gender-neutral United Nations standard that protects the vulnerable people an organization serves. A corporate workplace needs POSH, which is our core service; an organization serving vulnerable people needs PSEA. Dr. Priya has worked on both.

Six things: a validly constituted Internal Committee (Section 4), a written anti-harassment policy that is widely disseminated (Rule 13(a)), display of the penal consequences and the committee order at the workplace (Section 19(b)), awareness programs for employees and orientation for the committee at regular intervals (Section 19(c)), an annual report every calendar year (Section 21), and the number of cases in your organization’s annual report (Section 22). Manas can set up and support all six (awareness training is an optional add-on, or you can run it yourself). Sources: the Act · Rule 13.

Yes. The Act protects “a woman, of any age whether employed or not” at the workplace — so interns, trainees, contractors, consultants and visitors are covered, not only permanent staff (Section 2(a)).

Yes. The Act does not mention remote work expressly, but it does not limit the workplace to your office: it includes any place an employee visits arising out of or during the course of employment (Section 2(o)). Write remote, hybrid and online work into your policy — distributed and online-first companies still need a policy, a committee and training.

A district-level committee that every District Officer must constitute. It receives complaints from establishments that have no Internal Committee because they have fewer than ten workers, and complaints made against the employer himself (Section 6(1)). If an employer that should have an Internal Committee has not constituted one, a complaint also goes to the Local Committee (Section 9(1)).

It depends on whether you are a “small company”. Since 1 December 2025, a private company with paid-up capital up to ₹10 crore and turnover up to ₹100 crore is a small company, and its shorter Board’s Report does not carry the POSH statement. Subsidiaries and holding companies (including Indian arms of foreign groups), public companies and Section 8 companies are never small companies — their Board’s Report must confirm the Internal Committee and, since 14 July 2025, state complaints received, disposed of and pending beyond 90 days. Every employer, small or not, must still report its number of cases under Section 22 of the POSH Act — and skipping that is itself punishable under Section 26. Sources: Companies Act s.2(85) · Rules 8 & 8A · G.S.R. 357(E) · G.S.R. 880(E) · Sections 22 and 26.

The committee every employer with 10 or more employees must constitute, by an order in writing, to receive and inquire into complaints of sexual harassment (Section 4(1)). Section 4 names it the Internal Complaints Committee (ICC); the rest of the Act calls it the Internal Committee (Section 2(h)). Where your offices or administrative units are in different places, each one needs its own committee.

Someone from a non-governmental organization or association committed to the cause of women, or a person familiar with issues relating to sexual harassment (Section 4(2)(c)). The Rules define “a person familiar with issues relating to sexual harassment” only for Local Committees: a person with expertise on those issues, which may include a social worker with at least five years’ experience in work favorable to the empowerment of women, or a person familiar with labor, service, civil or criminal law (Rule 4). Dr. Priya is nominated on both grounds: as a psychologist familiar with workplace sexual harassment issues, and as President of Indradhanush Welfare Foundation, a registered NGO. Her credentials go with your nomination documents.

It is the clause that requires one member of the Internal Committee to come from an NGO or association committed to the cause of women, or to be a person familiar with issues relating to sexual harassment. It exists to bring a neutral, outside perspective to every inquiry. (Read Section 4)

Dr. Priya Dubey Sharma is an Applied, Behavioural & Organisational Psychologist (PhD, M.Phil) with over 18 years of experience, empaneled as an external member under Section 4(2)(c) through Indradhanush Welfare Foundation, a registered NGO she heads.

Yes. Where offices or administrative units are in different places, the POSH Act requires an Internal Committee at each of them, so a company operating in, say, three cities needs three committees. We set up a committee at every location — each with its own confidential complaint link, workplace posters and documents — under one account and one plan, priced by your total headcount across all offices, with Dr. Priya serving as the external member on all of them. (Section 4(1))

Yes. A complaint must be made in writing within three months of the incident, or of the last incident in a series; if she cannot put it in writing, committee members must help her. The committee can extend the limit by up to three more months, for reasons recorded in writing, if circumstances prevented her from complaining in time. Your portal date-stamps every complaint, so the timeline is clear from the start. (Section 9(1))

Through your private online portal. Each office has its own complaint link and QR code; the person complaining receives a reference code, and your committee members, Dr. Priya as your external member, and Manas are alerted by email the moment it is filed. The alert carries no complaint details, and it does not go to the business owner’s account. Every case carries the statutory deadlines, with the full record and documents in one place for the committee.

If you have 10 or more employees, you are already in breach of Section 4, and under Section 9 the complaint goes to the district’s Local Committee instead of your own. In the 2019 Indore case, that is how it was heard; the complaint was upheld, and the employer was directed to pay a ₹50,000 penalty and ₹25 lakh in compensation. Sources: the Act · MP High Court, 2019.

Yes, but only at the request of the woman who complained, and only before the inquiry begins. A monetary settlement cannot be the basis of conciliation; if a settlement is reached, the committee records it, gives copies to both parties, and no further inquiry is held (Section 10).

On the woman’s written request, the committee can recommend that the employer transfer her or the respondent to another workplace, grant her leave of up to three months — in addition to her normal leave — or give other prescribed relief while the inquiry runs, and the employer must implement it (Section 12).

The inquiry must be completed within 90 days (Section 11(4)); the committee reports its findings to the employer within 10 days of completing it, and the employer must act on the recommendations within 60 days (Section 13). If the allegation is proved, the recommendation can include action for misconduct under your service rules and a deduction from the respondent’s salary to compensate the woman. Source: Sections 11 and 13.

Yes. A person aggrieved by the committee’s recommendations, or by their non-implementation, can appeal to a court or tribunal under the applicable service rules or, where there are none, to the appellate authority under the Industrial Employment (Standing Orders) Act, 1946, within 90 days of the recommendations (Section 18 · Rule 11).

Only a complaint made knowing it to be false, or backed by a forged or misleading document, can lead to action against the complainant — and malicious intent must first be established through an inquiry. The Act is explicit that a mere inability to substantiate a complaint or provide adequate proof need not attract action (Section 14).

The Internal Committee. The complaint, the identities and addresses of the woman, the respondent and witnesses, and the inquiry, recommendations and action taken may not be published or made known to the public, press or media (Section 16); anyone handling the case who breaches this is liable to a penalty (Section 17). On our portal, full case details open only for your committee members and your external member, with the Manas team that supports them; owners and HR who are not on the committee see only the case status and deadlines. As your external member, Dr. Priya is bound by the same confidentiality, and by professional psychological ethics.

Yes. A complaint can be about anyone the woman alleges harassed her at the workplace, not only a co-worker, and the employer’s duty to provide a safe workplace expressly includes safety from people who come into contact with it (Section 19(a)). Where the perpetrator is not an employee, the employer must also help initiate action under the law at the workplace where the incident took place (Section 19(h)).

Yes. The POSH process runs alongside the criminal law: if she chooses to file a criminal complaint, the employer must assist her (Section 19(g)).

Your portal sets a 48-hour acknowledgement target (our service standard; the Act sets no acknowledgement deadline) on every new complaint and shows it to your committee, alongside the 90-day inquiry limit and the dates for the report and the employer’s action. Reminder emails go out as each date approaches, and anything overdue is flagged, so your committee does not lose track of the statutory timeline.

Yes. Dr. Priya takes part in your committee’s inquiry hearings and deliberations for every inquiry, as a committee member; that is covered by your plan. If you also want the paperwork handled, our Managed Inquiry service (₹18,000 per case) covers the case administration: notices, scheduling, hearing records and a draft inquiry report for the committee to decide on. Your committee still hears the parties and makes the findings, as the law requires.

Yes. Our Internal Committee capability training covers the full inquiry procedure — acknowledging a complaint, applying natural justice, handling evidence and witnesses, writing the inquiry report, and closing a case within the statutory 90 days. It is an optional add-on: ₹6,999 per online session, or ₹15,000 per day on-site plus travel and stay at actual cost.

Every calendar year. The Internal Committee prepares an annual report and submits it to the employer and the District Officer (Section 21), and the Rules fix what it contains: complaints received, complaints disposed of, cases pending for more than 90 days, workshops and awareness programs held, and the action taken (Rule 14). Manas prepares your Section 21 report from your portal records, for your committee to review and submit.

Two things, at a conspicuous place: the penal consequences of sexual harassment, and the order constituting your Internal Committee (Section 19(b)). The Rules also require you to declare the names and contact details of every committee member (Rule 13(e)).

The Act does not fix a frequency; many employers hold sessions at least once a year. The Act requires awareness programs for employees and orientation for Internal Committee members at regular intervals (Section 19(c)), the Rules add capacity- and skill-building for the committee (Rule 13), and the number of workshops held goes into your annual report (Rule 14).

SHe-Box — the Sexual Harassment electronic Box — is the Government of India’s online portal, run by the Ministry of Women and Child Development, where any woman can file a complaint of sexual harassment and workplaces register their Internal Committee details. Under Supreme Court directions, District Officers have been asked to survey workplaces and get their committee data onto it (PIB, Feb 2026).

Yes. Register on our portal, add your company and your committee, and your POSH policy, workplace posters, complaint link and compliance documents are generated for you. Once your plan is active, Dr. Priya is added as your external member and your signed documents are issued. If you would rather not do it alone, we will set it up with you.

Manas is based in Bhopal and works with companies across India, in any sector. Your external member, policy setup, compliance portal and training are delivered online wherever you are, and on-site training is available anywhere in the country.

Yes. Committee meetings, inquiry participation, policy setup and employee training are all delivered online, so we work with companies anywhere in India. In-person sessions are available anywhere in India on request; on-site training is ₹15,000 per day plus travel and stay at actual cost.

Almost all of it. Manas provides your external member, policy, committee documents, compliance portal, annual report preparation and, if you choose Managed Inquiry, the case administration for each inquiry, so your team does not have to build POSH expertise in-house. Two things the law keeps with you: your Internal Committee, including your own members, hears and decides each complaint, and the employer acts on its recommendations.

Yes. We deliver both the Internal Committee training and the employee awareness session on-site anywhere in India, or online — whichever suits you. Online sessions are ₹6,999 each; on-site training is ₹15,000 per day plus travel and stay at actual cost.

Yes. We review or draft your POSH policy, help you constitute or reconstitute your Internal Committee, and prepare your committee constitution order and appointment letters — all customized to your organization. Manas is not a law firm and does not give legal advice; we work alongside your legal counsel. If you need advice on your documents, have your counsel review them.

Yes. We prepare your Section 21 annual report each year from your portal records, and help you keep your committee, documents and SHe-Box registration current.

Yes. We guide you through registering your workplace and Internal Committee on the government SHe-Box portal — from nominating your nodal officer to verification — with your committee details prepared to enter, and help you keep them current each year. There is no public API for SHe-Box, so it is a guided registration.

We provide the workplace display posters and a confidential complaint mechanism — a QR code and link your employees can use to reach the committee directly — and we guide you on placing a physical complaint box wherever you want one.

Yes. Your portal generates a 10-poster workplace awareness series, co-branded for each office, covering consent, what harassment looks like, how to complain and your committee’s details, each carrying a confidential complaint QR code.

Yes. Your portal issues a dated POSH compliance-status certificate for each office, with a reference number and a checklist worked out from your actual records, that you can show in audits, tenders and vendor due-diligence. It is issued only while your plan is active and your committee meets the composition checks. It records your set-up status on the date issued; it is not a government certificate or a legal opinion.

Your portal keeps a compliance calendar that automatically tracks your annual return, your committee’s three-year tenure and your annual training, and emails reminders before each one falls due.

Yes. Your portal produces a one-click, audit-ready compliance pack: a single print-ready document with your compliance checklist, committee roster, complaint-log summary and document index, ready for an inspection or a client audit. Each tick on the checklist reflects your actual records, so it also shows anything still missing.

Yes. Every session gives you an attendance record, the session recording, and a training-completion certificate — the documentation you need to show the training took place, for an audit or your Section 21 annual report.

The POSH Act requires every Internal Committee to include one external member from outside your organization (Section 4(2)(c)). Dr. Priya Dubey Sharma is nominated to your committee in that role. She takes part in your committee’s inquiries, conciliation and decisions as a full member, helping make sure complaints are handled fairly and without pressure from management.

The law says the employer pays the external member’s fees or allowances (Section 4(4) of the Act, and Rule 3 of the POSH Rules, 2013). To protect her independence, our fees are fixed in advance, published on this page, and never depend on how a case turns out.

The Act requires a person from an organization committed to the cause of women, or a person familiar with issues relating to sexual harassment (Section 4(2)(c)). Dr. Priya is an Applied, Behavioural & Organisational Psychologist familiar with workplace sexual harassment matters, and is empaneled through Indradhanush Welfare Foundation, a registered NGO of which she is President. We share her credentials with your nomination documents.

The Act requires the inquiry to be completed within 90 days, and the committee’s report to reach the employer within 10 days after that. The employer must act on the recommendations within 60 days (Sections 11 and 13). Your portal shows these deadlines on every case.

Yes. You invite each committee member by email, and they set their own password. Each member sees only the committees they sit on, and their access ends as soon as they are removed. Manas and your external member are emailed whenever someone is given, or loses, committee access, so changes to who can see cases are always visible.

Yes, within 14 days of paying for the annual plan, as long as no signed documents (such as Dr. Priya’s nomination letter or your compliance certificate) have been issued yet. Email manu@manas365.com and we refund the plan fee in full to the original payment method within 7 working days. After 14 days, or once signed documents are issued, you can still cancel any time: the renewal stops, and the year already paid is not refunded. Training or inquiry work already delivered is not refundable. Full terms: refund and cancellation policy.

No. The complaint form, case pages and portal carry no advertising or analytics trackers, are hidden from search engines, and do not pass their address on to other websites.

Yes. Every factory or unit with 10 or more employees needs an Internal Committee, and contract workers supplied by a contractor count toward the 10. Units at different places each need a committee. More: POSH for MSMEs and factories.

Yes. There is no startup exemption. Interns and trainees count, remote teams are covered, and companies that are not “small companies” must also report POSH in the Board’s Report. More: POSH for startups and IT companies.

Yes, to staff at any hospital, nursing home or clinic with 10 or more employees. The Act’s definition of workplace expressly includes hospitals and nursing homes. Harassment by a patient or visitor is covered too, so night shifts and wards need a clear way to complain.

Yes, for teachers and staff: an educational institution with 10 or more employees needs an Internal Committee. Complaints by college students are also covered by the UGC’s 2015 regulations for higher education institutions, and anything involving a child falls under the POCSO Act, 2012, which has its own mandatory reporting rules. Take legal advice on how these fit together.

Yes, once a workplace has 10 or more employees, counting part-time, temporary and daily-wage staff. Harassment by customers or guests at the workplace is covered as well.

Yes. Sites and offices with 10 or more employees, including workers engaged through contractors, need an Internal Committee. Where a site has fewer than 10, complaints go to the district’s Local Committee.

Yes. The Act covers non-governmental organizations, trusts and societies, and volunteers count as employees. An organization that works with children or vulnerable adults may also need a wider safeguarding (PSEA) policy.

Yes. A firm with 10 or more people, counting articled assistants, trainees and interns, needs an Internal Committee. Partnerships and LLPs are covered like companies.