POSH (Sexual Harassment) Compliance & Advisory

What the Law Actually Requires

Compliance under POSH isn’t limited to hanging a policy on the notice board. Organisations must:

• Constitute an Internal Committee (IC) at every office location, with a senior woman employee as presiding officer and an external member with expertise in the subject.
• Draft and circulate a POSH policy clearly outlining the definition of sexual harassment, complaint procedures, and disciplinary consequences.
• Conduct regular awareness training for employees and sensitisation sessions for IC members.
• File an Annual Return disclosing the number of complaints received and resolved, as part of the company’s mandatory disclosures.
• Ensure timely inquiry and resolution of complaints, typically within 90 days, following due process and confidentiality norms.

Non-compliance isn’t a minor lapse. Penalties range from monetary fines to cancellation of business licenses, and courts have increasingly held company leadership personally accountable for procedural failures.

Why “Having a Policy” Isn’t Enough

We frequently encounter organisations that have a policy document but no functioning Internal Committee, or an IC that exists on paper but has never been trained to handle a real complaint. A POSH framework is only as strong as its execution. Poorly conducted inquiries — whether due to bias, procedural errors, or lack of legal grounding — can expose a company to litigation from both complainants and respondents.

Effective compliance means the IC understands natural justice principles, evidence handling, and how to write a legally sound inquiry report. It also means employees trust the mechanism enough to actually use it, which requires consistent communication and visible organisational commitment, not a once-a-year email reminder.

How Bakshi and Associates Helps

Our POSH Compliance & Advisory practice partners with organisations to move beyond paperwork:

• IC formation and structuring, including sourcing qualified external members
• Policy drafting and review aligned with the latest amendments and case law
• Employee and IC training conducted by experienced facilitators
• Inquiry support and legal advisory during active complaints
• Compliance audits to identify and close gaps before they become liabilities

We work with startups scaling their first HR policies as well as established enterprises managing complex, multi-location compliance. Our goal is simple: build workplaces where policy translates into practice, and employees feel genuinely protected.