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CLIENT PROPOSAL: POSH COMPLIANCE SERVICES

EXECUTIVE SUMMARY

Following our recent conversation, we are pleased to present this comprehensive proposal for POSH (Prevention of Sexual Harassment) Compliance Services as mandated under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

At Salahkaar Consultants, we don’t just deliver compliance—we build cultures of respect, accountability, and psychological safety.

With 40+ years of expertise in organizational behavior and HR consulting, backed by the Council of Behavioral Research (CBR), we bring a unique blend of legal rigor, behavioral science, and practical execution to workplace safety. Our POSH consulting services are designed to protect your organization from legal, reputational, and operational risks while empowering your employees to thrive in a safe environment.

This proposal outlines a comprehensive, audit-ready POSH compliance program tailored to your needs, covering policy development, Internal Committee (IC) support, employee training, annual reporting, and ongoing advisory.

UNDERSTANDING YOUR COMPLIANCE MANDATE

What the POSH Act Requires:

Every organization with 10 or more employees must:

Establish an Internal Committee (IC) with at least one external member

Develop and display a written POSH Policy

Conduct annual awareness training for all employees

Provide a confidential complaint mechanism Complete inquiries within 90 days of complaint filing

Submit an Annual POSH Report to the District Officer

Register on SHE-Box Portal (Ministry of Women & Child Development)

Display IC member details and penal consequences at the workplace

Maintain records of complaints, inquiries, and training for audit purposes

Ensure IC members receive specialized training on inquiry procedures

Consequences of Non-Compliance:

• Monetary Penalties: Up to ₹50,000 (and higher for repeat offenses)
• License Cancellation: For severe or repeated non-compliance
• Reputational Risk: In an era of social media and Glassdoor reviews
• Legal Exposure: Civil and criminal liability for organizations and directors
• Talent Impact: Employees (especially women) avoid non-compliant workplaces

OUR PROPOSED SOLUTION:

COMPREHENSIVE POSH COMPLIANCE PROGRAM

SCOPE OF SERVICES

1. EXTERNAL MEMBER SERVICES (Annual Retainer)

What We Deliver:

• External Member Representation: Act as the mandatory External Member of your Internal Committee (IC) as per Section 4(2)(d) of the POSH Act
• Quarterly IC Meetings: Attend all scheduled IC meetings (minimum 4 per year)
• Complaint Inquiry Participation: Participate in inquiry proceedings whenever a complaint is filed (as needed)
• Compliance Advisory: Ongoing guidance on IC operations, complaint handling, and legal updates
• Annual Report Support: Review and validate annual POSH report for accuracy and legal sufficiency

Why This Matters:
The law mandates at least one external member with expertise in workplace harassment. Our role ensures IC proceedings are independent, objective, legally defensible, and conducted per principles of natural justice.

Deliverables:

• Formal External Member appointment letter
• Quarterly IC meeting minutes (co-signed)
• Inquiry participation records
• Compliance advisory (email/phone support)

2. POSH POLICY DEVELOPMENT & REVIEW

What We Deliver:

• Comprehensive POSH Policy: Customized to [Company Name]’s industry, organizational structure, and workplace culture
• Legal Compliance: Aligned with POSH Act 2013, latest amendments, and Supreme Court guidelines
• Coverage: Addresses physical harassment, verbal harassment, digital harassment, third-party harassment, contractor obligations, and remote work scenarios
• Employee-Friendly Summary: 1-2 page simplified version for quick reference

Deliverables:

• Full POSH Policy document (15-25 pages)
• Employee handbook summary
• Display-ready policy posters (PDF + print-ready)

3. DISPLAY MATERIALS & COMMUNICATION SUPPORT

What We Deliver:

• Mandatory Display Boards: Compliant with Section 19 of the POSH Act
  • POSH Policy summary
  • IC member names and contact details
  • Penal consequences for harassment
  • Complaint filing process
• Digital Assets: For email signatures, intranet, employee portals
• Multilingual Support: Hindi + English (regional languages available on request)

Deliverables:

• 2 x A3 size display posters (physical + digital)
• Email templates (policy rollout, training invites)
• Intranet content (copy-paste ready)

4. SHE-BOX PORTAL REGISTRATION & MANAGEMENT

What We Deliver:

• End-to-End Registration: Complete setup on SHe-Box portal (Ministry of WCD)
• IC Member Registration: Upload IC details and organizational information
• Training on SHe-Box Management: How to monitor and respond to SHe-Box complaints
• Ongoing Support: Guidance on portal updates and compliance

Why This Matters:
Employees can file complaints directly on SHe-Box. Organizations must be registered, monitor the portal regularly, and respond within mandated timelines to avoid escalations.

Deliverables:

• SHE-Box registration certificate
• User guide for SHe-Box portal management
• Ongoing advisory on SHe-Box complaints

5. EMPLOYEE AWARENESS TRAINING

What We Deliver:

Session 1: All-Employee POSH Awareness (1.5 – 2 hours)

• Content Coverage:
  • Legal definition of sexual harassment (with real-world examples)
  • Types of harassment: Verbal, visual, physical, quid pro quo, hostile work environment
  • Digital harassment (emails, chats, social media, video calls)
  • How to report complaints (formal vs informal mechanisms)
  • Complainant rights and confidentiality protections
  • Respondent rights and fair inquiry process
  • Bystander intervention strategies
  • Zero tolerance for harassment + zero tolerance for false complaints
  • Q&A and anonymous feedback
• Delivery Options: In-person (at your office), virtual (Zoom/Teams), or hybrid
• Batch Size: Up to 100 participants per session (additional batches quoted separately)
• Customization: Industry-specific scenarios, multilingual delivery available

Post-Training Support:

• Attendance records and participant certificates (audit-ready)
• Training presentation slides (for future reference)
• Pre/post-training assessment (to measure knowledge retention)
• Anonymous feedback survey

6. INTERNAL COMMITTEE (IC) TRAINING

What We Deliver:

Session 2: IC-Specific Training (Approx. 1 hour)

• Content Coverage:
  • Roles and responsibilities of IC members
  • Inquiry procedures and timelines (90-day mandate)
  • Principles of natural justice (audi alteram partem)
  • Evidence gathering and documentation
  • Conducting sensitive conversations with complainants and respondents
  • Avoiding common pitfalls (bias, procedural errors, inadequate documentation)
  • Confidentiality and data protection
  • Legal implications of inquiry findings
  • Action recommendations and follow-up
• Audience: Presiding Officer + IC members + HR representatives
• Delivery: In-person or virtual

Deliverables:

• IC training presentation
• SOP for complaint inquiry (step-by-step guide)
• Templates (complaint form, inquiry report, action memo)
• IC member certificates

7. ANNUAL POSH REPORT PREPARATION & SUBMISSION

What We Deliver:

• Comprehensive Annual Report: As mandated under Section 21 of the POSH Act
• Includes:
  • Number of complaints received
  • Nature of complaints
  • Status of inquiries (resolved, pending, dismissed)
  • Actions taken against respondents
  • Training sessions conducted
  • IC meeting summary
  • Compliance checklist
• Submission Support: Draft ready for submission to District Officer (where applicable)
• Board-Ready Summary: Executive summary for governance review

Deliverables:

• Annual POSH Report (10-15 pages)
• District Officer submission-ready version
• Board presentation summary (PPT)

8. POSH COMPLIANCE AUDIT (Optional Add-On)

What We Deliver:

• Comprehensive Compliance Health Check covering:
  • Policy adequacy and legal alignment
  • IC constitution and functionality
  • Training records and employee coverage
  • Display and communication compliance
  • Complaint handling documentation
  • SHe-Box registration status
  • Annual report completeness
  • Record-keeping and data security
• Gap Analysis Report: Prioritized remediation roadmap with timelines
• Compliance Certificate: Upon achieving full compliance

Deliverables:

• Audit checklist (50+ parameters)
• Gap analysis report with action plan
• Compliance certificate (if applicable)

IMPLEMENTATION TIMELINE

Phase 1: Foundation (Week 1-4)

Phase 2: Training & Capacity Building (Week 5-8)

Phase 3: Operationalization (Month 3-12)

WHY SALAHKAAR CONSULTANTS?

✓ 40+ Years of Excellence

Backed by the Council of Behavioral Research (CBR), we bring academic rigor and real-world execution to workplace safety.

✓ ISO 9001:2015 Certified

Our quality management systems ensure every engagement meets global standards.

✓ Multidisciplinary Expertise

We combine legal compliance, organizational psychology, HR best practices, and change management—creating holistic solutions, not patchwork fixes.

✓ Audit-Ready Deliverables

Every document, record, and report is designed to withstand scrutiny from labor inspectors, auditors, courts, and due diligence processes (M&A, IPO, ESG ratings).

✓ Confidentiality & Sensitivity

We handle sensitive matters with empathy, discretion, and professionalism—ensuring complainant safety and respondent fairness.

✓ Long-Term Partnership Orientation

We’re not transactional vendors. We’re strategic partners invested in your organizational culture and employee well-being.

NEXT STEPS

Step 1: Proposal Review

Please review this proposal and share any questions or requests for customization.

Step 2: Contracting

Upon acceptance, we will share a Master Services Agreement (MSA) outlining terms, confidentiality, liability, and governance.

Step 3: Kickoff

We can commence work within 7 days of contract signing, with full compliance achieved within 30-45 days.

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THE  POSH COGNIZANCE

• Spread the awareness,Make the work environment a better place. 

Societal Fact Alert! 

We live in a gendered society. Today one of the major concerns stand to be sexual harrasment of women in their workplaces. In Fact this poignant issue came to light in an elaborate manner and gained massive significance with the popular “#MeToo ” Movement. The term, “Me Too” was first exercised under this context in the year 2006, by Tarana Burke on MySpace (social media platform). She is a social activist and had survived sexual assault, herself. Since the phrase was used in social media, it attained a global audience. In 2017, Alyssa Milano made it a hastag which was an ongoing trend on Twitter and uplift women into revealing their experiences with sexual harrasment especially in their workplaces. This would make women feel accompanied and they would choose to speak up about it. 

Subsequently talking particularly about India, the “#MeToo” Movement particularly hit the Bollywood industry. Many women called out prominent actors, directors journalists and others alleging sexual harrasment. On this, the court asserted that the production units of the film crew must form a joint committee in order to  take definitive actions against such allegations. They were also strictly asked to act as per the POSH Act which was established in 2013. The POSH Act was refered to as the prevention of sexual harassment which was passed by the government in 2013. 

Even though the POSH Act was established in the year 2013, the majority of the people of the society today are clearly unaware of the Act and it’s significance. The POSH Act vividly describes sexual harrasment and outlines methods to lodge a complain and an inquiry of the action with the purpose of procuring justice. 

The Act expanded on the Vishakha guidelines that were created in 1997. It imposed on each and every company, three legally binding  key components that needed to be followed. These components were “prohibition, prevention, and redress” However, these laws are still not fully understood or carried out in many organisations. 

THE POSH POLICY: WHAT CONSTITUTES SEXUAL HARRASMENT:-

The 2013 Act released a handbook which gave detailed conditions to what constitutes sexual harrasment. 

• Inappropriate intimidating physical advances.
• Commanding or calling in sexual favours.
• Any verbal or non-verbal action of sexual nature. 
• Displaying pornography or pornographic content in any form. 
• Making remarks which are sexually coloured or sexually abusive towards the employee. 

If any of the above conditions were meted out, directly or indirectly, the law would actively categorise it as sexual harrasment and would accept all complaints in adherence to the rules of the policy. 

Let us make an attempt to understand how the POSH Act works and what procedures have been laid out in lieu of it. 

The fundamental step for every employer was to form an “Internal Complaints Committee (ICC)”. It is the most significant wing of the POSH Act implementation process. The term of an Internal Complaint Committee is three years. 

The statutory definitions of the various forms of sexual harrasment are given. It gives the woman a choice, wherein she can choose to register a complaint or not. However, the law specifies that  the complaint can only “within three months from the date of the incident”,can the complaint be lodged. Although the ICC could “extend time limit”, if they deem that circumstances dictated an inability for the victim to have complained. 

THE POSH POLICY: INTERNAL COMPLAINTS COMMITTEE (ICC)

Let us look at the Internal Complaints Committee (ICC) as a body. The ICC, which consists of more than 10 employees, must have three types of members. 

• Presiding Officer:- Every committee must have a head. Thus the criteria for chairperson of this committee is that, it must be a senior female employee of the company which will make things more comprehensible and easily approachable for the complainee. 
• Employee Member:- There must be significant representation from the company as well. So at least two members with an intermediate knowledge of the law,  preferably well aware and actively involved in the causes and problems faced by women. 
• External Member:- External Representation is extremely necessary along with internal presence. The External Member must possess an in-depth insight into the concept of sexual harrasment from a humanitarian and non-government perspective. 

The role of an external member is to maintain an unbiased procedure during an inquiry. An external member must attend regular meetings with the Internal Complaints Committee and jot down the Minutes of the meeting. He/She must ensure than all rules and regulations in compliance to law is being followed. The External Member must aid the Internal Complaints Committee to follow all the protocols. He/ She must remain impartial and contribute to the organization by trying to prevent sexual harrasment in the workplace environment. 

THE POSH POLICY PROCEDURE :-

A sexual harrasment complaint can be registered by a woman, “of any age whether employed or not.” Once registered, the procedure runs as follows:-

• The Internal Complaints Committee must look into the matter urgently. If requested by the victim, the ICC can “at the request of the aggrieved woman, take steps to settle the matter between her and the respondent through conciliation” The condition being that there would be no monetary resolution.
• The Internal Complaints company works more like a civil court where police officers are given to investigate and lead the inquiry. The members of the committee have the authority to question any individual related to the case under the oath. 
• The inquiry must be wrapped up within 90 days and the report and findings from the inquiry must be provided to the Employer within 10 days in time. The development of the case must be made aware to both the parties. However during this process, the identity of the woman along with the witnesses and actions taken on particular instances must be concealed and not make public

POSH POLICY PROCEDURE: THE AFTERMATH:-

• If the accusations are proven to be true, then action must be taken by the Employer, “in accordance with the provisions of the service rules”. The salary amount of the guilty can be reduced as per appropriate. 
• The individual woman in concern must be well compensated for her emotional distress along with her medical expenses if necessary. Whatever opportunities that were lost by her must also be made up. 

POSH POLICY: THE CATCH

” Every coin has two sides” and so does this policy. If the accusations are deemed to be untrue/ containing false evidence then the law demands action to be taken against the accuser “in accordance with the provisions of the service rules”. However it also facilitates that action cannot be pushed against an individual on the basis of inability to gather evidence or substantiate the claim. 

A major part of our society still remains unaware of laws that are issued in the better interests of citizens. The POSH POLICY was perpetrated in 2013 and many of us are still not fully acquainted with the procedures. Many women have not reached out when they needed to and they must be made aware of the help that the laws entail for them.  

With the technological advancement of society we are being thrown off course on the matters of humanity. In workplaces we are concerned with increasing productivity but forget to maintain etiquettes and courtesies which make our colleagues feel comfortable in our presence. This in turn causes degradation in the quality of work and thus reduces productivity. Hence we must work towards making the office environment a safe place for all genders. With the employees feeling safe and satisfied, one can ensure the growth of a company.