Anti-Sexual Harassment (POSH) Policy Template

# Anti-Sexual Harassment Policy (POSH)

[Company Name] is committed to providing a safe, respectful, and inclusive workplace free from sexual harassment. This policy complies with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

This policy applies to: • All employees (permanent, temporary, contractual, interns) • Visitors, clients, vendors, and third parties in workplace premises • Workplace includes office, remote work locations, transport provided by employer, and work-related events

As per Section 2(n) of POSH Act, sexual harassment includes: • Physical contact and advances involving unwelcome and explicit sexual overtures • Demand or request for sexual favours • Making sexually coloured remarks • Showing pornography • Any other unwelcome physical, verbal, or non-verbal conduct of sexual nature 3.1 Circumstances Constituting Sexual Harassment • Implied or explicit promise of preferential treatment • Implied or explicit threat of detrimental treatment • Interference with work or creating hostile work environment • Humiliating treatment likely to affect health or safety

4.1 Constitution • Presiding Officer: Senior woman employee at decision-making level • Members: Two employees committed to women's causes/social work • External Member: From NGO/association committed to women's cause • Minimum 50% women members • Term: 3 years 4.2 Contact Information • Presiding Officer: [Name, Designation, Email, Phone] • Members: [Names and Contact Details] • External Member: [Name and Contact Details]

5.1 Filing a Complaint • Written complaint to ICC within 3 months of incident (extendable by 3 months) • Complaint must contain: Description of incident, date/time/location, names of witnesses • Anonymous complaints: Not entertained as per law, but ICC may take suo motu cognizance • Assistance: ICC to provide assistance in writing complaint if needed 5.2 Conciliation • ICC may attempt conciliation before inquiry if complainant requests • Monetary settlement not allowed as basis of conciliation • If conciliation successful: Record settlement, no further action • If conciliation fails: Proceed to inquiry 5.3 Inquiry Process • Copy of complaint to respondent within 7 working days • Respondent to file reply within 10 working days • ICC to complete inquiry within 90 days • Both parties have right to representation • ICC has powers of civil court for summoning witnesses and documents • Confidentiality maintained throughout 5.4 Timeline • Complaint receipt: Day 0 • Respondent notice: Within 7 days • Reply submission: Within 10 days of notice • Inquiry completion: Within 90 days • Report submission: Within 10 days of inquiry completion • Action by employer: Within 60 days of report

6.1 If Complaint Proved • Written apology • Warning, reprimand, or censure • Withholding promotion or pay raise • Termination from employment • Undergoing counselling • Community service • Deduction from salary (compensation to complainant) 6.2 Compensation • Mental trauma, pain, suffering • Medical expenses • Loss of career opportunity • Income and financial status of respondent • Feasibility of payment 6.3 If Complaint Malicious/False • Action against complainant (not for mere inability to prove) • Disciplinary action as per service rules 6.4 If Third Party Harasser • Action against service provider/contractor • Debar from future engagement

• Display POSH policy prominently • Conduct awareness programs quarterly • Organize ICC training annually • Include POSH in onboarding • File annual report with District Officer • Maintain confidentiality • No victimization of complainant/witnesses • Assist in legal proceedings

File with District Officer by January 31 each year containing: • Number of complaints received • Number of complaints disposed • Number of cases pending > 90 days • Nature of action taken • Number of awareness programs conducted

• Fine up to ₹50,000 for first offence • Double penalty + cancellation of licence/registration for repeat offence

• Either party may appeal to court/tribunal within 90 days of recommendations