Your PoSH Policy Should Work for Your People, Not Just Sit in a Folder
A PoSH policy is a legal requirement for every organisation with 10 or more employees in India. Sol helps you get it right the first time, and keeps it current as your organisation grows.
Mandatory
For all organisations with 10+ employees
Industry Agnostic
Applies across all sectors and legal structures
Tailored
Every policy customised to your organisation
End to End
Drafting, review, and dissemination support
Mandatory
Applies across all sectors and legal structures
Tailored
Every policy customised to your organisation
End to End
Drafting, review, and dissemination support
What is Posh?
Three pillars
who is covered
What counts?
Employer duties
Internal commitee
Complaint Process
why it matters
The Foundation
What Is a PoSH Policy and Why Is It Mandatory?
A PoSH policy is a formal document that lays out an organisation's commitment to preventing and addressing sexual harassment at the workplace.
It defines what sexual harassment is, specifies how complaints are to be raised and resolved, and outlines the rights and responsibilities of every person in the organisation.
The law does not just require you to have a policy. It requires you to widely disseminate it, meaning all employees must have active access to it, not just HR leadership.
Critically, having a policy on paper is not the same as compliance. The policy must be clear enough for every employee to understand, accurate to the Act, and genuinely reflective of how your organisation works.
What the Act Says About Policy
Section 19 of the PoSH Act and Rule 13 of the Rules require every employer to formulate and widely disseminate an internal policy for the prohibition, prevention, and redressal of sexual harassment. This policy must promote gender-sensitive safe spaces and address underlying factors that contribute to a hostile work environment.
Policy Elements
What Must a PoSH Policy Include?
A compliant PoSH policy covers specific elements required under the Act. Here is what every policy must address to be legally sound and practically useful.
1
Opening Statement and Commitment
The policy must begin with a clear statement reaffirming the organisation's commitment to a safe, respectful workplace and zero tolerance towards any form of sexual harassment. This sets the tone and signals to every employee that leadership takes this seriously.
2
Scope and Applicability
The policy must clearly define who it covers and where it applies. This includes all categories of employees and the full scope of "workplace" as defined under the Act, covering field visits, travel, off-site events, and digital communication channels.
3
Definitions
Key terms including sexual harassment, aggrieved woman, complainant, respondent, employee, employer, and workplace must be defined precisely, drawing from the definitions in the Act. Ambiguity in definitions is one of the most common and costly policy gaps.
4
Forms and Examples of Sexual Harassment
The policy must explain what constitutes sexual harassment, covering both quid pro quo harassment and hostile work environment harassment, and should include practical examples that employees can relate to. The act lists five specific circumstances that are deemed to constitute harassment.
5
Internal Committee Details
The process for filing a complaint, the steps that follow, the timelines at each stage, and protections against retaliation must all be set out clearly. Employees should be able to read the policy and know exactly what happens when a complaint is filed.
6
Complaint Procedure and Timelines
The Act requires employers to recognise sexual harassment as a formal misconduct under service rules, wherever applicable. It must be handled with the same seriousness as any other professional violation.
7
Confidentiality Protections
The policy must state that all complaints and proceedings are confidential and explain what that means in practice. Breaches of confidentiality are a punishable offence under the Act, and the policy must make this clear.
8
Consequences for Violations
The policy must explain the consequences of sexual harassment and of filing a malicious complaint. Penalties for the respondent if harassment is proven, and disciplinary action for false complaints, must both be stated. This maintains fairness and deters misuse.
How Sol Helps
PoSH Policy Services from Sol
Whether you are starting from scratch or have an existing policy that needs attention, Sol provides focused, expert support for every stage of the process.
Policy Drafting
We draft a PoSH policy built specifically for your organisation. Not a template with your name dropped in, but a policy that reflects how your workplace actually functions, who your employees are, and what your values look like in practice.
We begin with a discovery call to organisation your sector, team structure, existing practices, and any other concerns. Everything that follows is built on that foundation.
- Discovery call to understand your organisation
- Legally compliant with the PoSH Act, 2013
- Written in plain language your employees will understand
- Covers all required elements under the Act and Rules
- Guidance on dissemination and display obligations
Policy Review
If you already have a PoSH policy, a review by an expert ensures it is still current, legally compliant, and free from gaps that could expose your organisation. Many policies were drafted years ago and have not been updated to reflect changes in law or practice.
We evaluate your existing policy against the Act, the Rules, and current best practice, then provide clear recommendations so you know exactly what needs to change and why.
- Line-by-line evaluation against the Act and Rules
- Identification of gaps, ambiguities, and outdated clauses
- Written report with prioritised recommendations
- Option to revise and update the policy with Sol
- Suitable for annual compliance reviews and audits
- A 30-minute call to discuss any questions or clarifications arising from the comments shared.
- drafting services not included
Not sure which service you need? Most organisations that contact us start with a discovery call.
The Bigger Picture
Why a Good PoSH Policy Is More Than a Legal Requirement
A well-drafted PoSH policy does more than keep you on the right side of the law. It shapes how people experience your workplace every single day.
It Meets Your Legal Obligation
It Builds Trust With Employees
It Signals Safety for Women
It Protects Fairness for Everyone
It Supports Your IC
It Reflects Your Organisation's Values
What to Avoid
Common PoSH Policy Mistakes We See
Most compliance failures do not come from organisations that do not care. They come from organisations that relied on a generic template or skipped a review for a year too long.
Copied Templates
Using a generic downloaded policy without customising it to your organisation's structure, sector, and culture. A template that does not reflect how your workplace operates will fail in practice.
Filed and Forgotten
A policy that exists in an HR folder but has never been shared with employees, displayed at the workplace, or explained during onboarding is not a compliant policy under the Act.
Never Reviewed
Policies drafted three or five years ago may not reflect amendments, updated guidance, or changes in the organisation. An annual review is good practice. A review every few years is the minimum.
Jargon-Heavy Language
A policy written in dense legal language that most employees will not read or understand defeats its own purpose. The most protective policies are the ones that are actually read and understood.
Missing Digital Workplace Coverage
Many older policies do not cover harassment through digital channels, remote work situations, or work-related social media. These gaps leave real risks unaddressed.
Unclear Complaint Process
If an employee cannot read your policy and know exactly how to file a complaint, who to file it with, and what will happen next, the policy needs to be rewritten.
The Sol Process
How We Work With You
We keep the process simple and transparent. Here is what working with Sol on a PoSH policy looks like from start to finish.
Step 1
Discovery Call
This is where we listen, not pitch
Step 2
Review or Draft
For a drafting engagement, we develop a full first draft based on what we learned, aligned with the Act and your organisation's values. For a review, we evaluate your existing policy and produce a written findings report.
Step 3
Your Feedback
We walk you through the draft or report, answer your questions, and incorporate your feedback. The goal is a policy your HR team understands and stands behind, not one that was handed over and filed.
Step 4
Final Delivery
You receive a final, ready-to-use policy document. We also provide guidance on how to share it, display it, and introduce it to your workforce so it serves its purpose from day one.
What Sets Sol's Approach Apart
We do not use a one-size-fits-all template. Every policy Sol drafts or reviews starts with a genuine understanding of your organisation. We believe a PoSH policy should read like it was written for your people, because it should be.
Our consultants bring both legal knowledge and ground-level experience. We have worked with organisations across a wide range of sectors in India, which means we understand the practical realities that generic policies tend to miss.
A policy is just the beginning
- IC formation and training
- Employee awareness workshops
- Annual compliance support
- Complaint management guidance
- Full PoSH audit services
Common Questions
Frequently Asked Questions
Questions we are often asked by HR teams, founders, and compliance officers when they first reach out to us.
Do we really need a PoSH policy if we have fewer than 10 employees?
The mandatory requirement to constitute an Internal Committee and maintain a formal policy applies to organisations with 10 or more employees. However, the PoSH Act itself applies to all workplaces regardless of size. Smaller organisations are not exempt. Complaints from employees of smaller organisations are handled by the Local Committee at the district level. As you approach or cross the 10-employee threshold, having a policy in place from the outset is strongly advisable.
Can we use a template policy we found online?
You can, but most template policies carry significant risk. Many are outdated, lack sector-specific relevance, or miss elements required under the Act and Rules. A policy that exists but is deficient can still create legal liability. More practically, a generic policy that does not reflect your workplace, your structure, or your values is unlikely to actually be used or trusted by your employees, which defeats its purpose entirely.
How often should a PoSH policy be reviewed?
We recommend reviewing your PoSH policy at least once a year as part of your annual compliance cycle. A review is also warranted after significant organisational changes such as a merger, major workforce expansion, or shift to a remote or hybrid work model. Any time there are updates to related legislation or guidance, the policy should be checked against those changes.
Does the policy need to be translated into regional languages?
The Act requires that the policy be "widely disseminated," which means it must be accessible and understandable to all employees. If a significant portion of your workforce is more comfortable in a regional language than in English, providing a translated version is both a legal requirement in spirit and the right thing to do. Sol can advise on this based on your workforce profile.
We already have a policy. Why do we need a review?
Policies drafted several years ago may not reflect judicial interpretations, updated guidance, or evolving workplace norms such as digital communication and remote work. Many policies we review also contain gaps in the complaint process, undefined terms, or missing provisions around confidentiality and retaliation. A review gives you certainty that what you have will hold up when it is actually needed.
How long does it take for Sol to draft or review a policy?
Timelines vary depending on the size and complexity of your organisation. Please reach out to us to discuss your requirements, and we'll provide an estimated timeline based on your specific needs.
Let's Build a Policy That Works for Your People
Whether you need a policy drafted from scratch or want a professional review of what you already have, Sol is here to help you get it right.