What is the POSH Act, 2013?

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 is the Indian law that requires employers to prevent sexual harassment, set up a complaint mechanism and redress complaints in a fair and time-bound manner.

Is an Internal Committee mandatory?

Yes. Under Section 4 of the POSH Act, 2013, every employer with 10 or more employees must constitute an Internal Committee (IC) at each office or branch. Workplaces with fewer than 10 employees are covered by the Local Committee set up by the District Officer.

What is the time limit to file a complaint?

A complaint should be made in writing within 3 months of the incident (or of the last incident in a series). The committee can extend this by another 3 months if circumstances prevented the woman from filing earlier.

How long does a POSH inquiry take?

The Internal Committee must complete its inquiry within 90 days of receiving the complaint and share its report with the employer within 10 days of completing it. The employer must act on the recommendations within 60 days.

Can Poshaw help my organisation comply?

Yes. From policy drafting and IC formation to training and annual reports, we provide end-to-end POSH compliance support. Contact us for a free consultation.

SHe-Box Compliance Checklist: Guide for Employers

The landscape of workplace compliance in India is evolving rapidly. While many organizations have successfully implemented POSH policies and constituted Internal Committees (ICs), compliance today extends far beyond the basics.

To bridge the gap between administrative tokenism and genuine workplace safety, the Ministry of Women and Child Development has introduced the SHe-Box (Sexual Harassment Electronic Box) Voluntary Compliance Checklist. This tool provides employers with a structured, transparent framework to evaluate and strengthen their adherence to the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act).

This checklist is far more than a routine compliance document—it functions as a proactive self-assessment tool designed to help organizations uncover hidden vulnerabilities, optimize workplace safety, and cultivate an inclusive culture.

What is the SHe-Box Compliance Checklist?

SHe-Box is the Government of India’s centralized online portal designed to streamline complaint management for women facing workplace sexual harassment. Expanding on this infrastructure, the voluntary compliance checklist enables organizations to systematically review whether they meet the statutory requirements of the POSH Act.

The framework is categorized into five distinct pillars, covering policy circulation, Internal Committee (IC) constitution, employee support, employer responsibilities, and digital portal onboarding.

Part A: POSH Policy and Internal Committee Compliance

Every organization covered under the POSH Act must ensure its foundational structures are legally sound. The checklist requires employers to verify key compliance markers:

Policy Formulation & Circulation: A formal POSH policy must be drafted, adopted, and actively distributed to all employees, including permanent staff, interns, and contractual workers.
Visible Display: The policy must be prominently displayed across physical workplaces and digital intranets.
Virtual Inclusion: Policies must explicitly extend protection to employees working remotely or in hybrid arrangements.
IC Constitution Mandates: An Internal Committee must be established at every applicable administrative unit or office.
Committee Composition: The IC must include at least four members, with a mandatory requirement that at least 50% of the members are women.
Leadership & External Oversight: A senior woman employee must head the committee as the Presiding Officer, alongside a mandatory External Member sourced from an NGO or organization committed to women's causes.

Part B: Support Systems for the Aggrieved Woman

Regulatory compliance must prioritize the psychological safety and well-being of the complainant. An effective POSH framework requires structured support mechanisms:

Accessible Channels: Organizations should offer multiple, confidential avenues for raising grievances, such as dedicated emails, physical drop-boxes, or online forms.
Prompt Acknowledgment: Complaints must be formally acknowledged without unnecessary administrative delays.
Strict Confidentiality: Complete discretion must be maintained regarding the identities of all parties and witnesses throughout the inquiry.
Interim Relief: Mechanisms must allow for interim measures (such as transfer or leave) when requested and legally justified.
Protection Against Retaliation: A zero-tolerance policy against victimization of complainants or witnesses must be enforced.
Counselling Support: Access to professional counseling or legal guidance should be made available when needed.

Part C: Awareness, Training, and Capacity Building

A well-drafted policy on paper is ineffective without continuous education. Continuous capacity building minimizes organizational risk and drives behavioral change:

IC Skill Enhancement: Internal Committee members must undergo periodic training covering inquiry procedures, natural justice, and evidence evaluation.
Employee Sensitization: Regular awareness workshops must be conducted to educate staff on their rights, acceptable office conduct, and reporting protocols.

Part D: Broad Employer Responsibilities

Under the POSH Act, statutory obligations extend well past the initial formation of an IC. Employers must actively monitor:

Timeline Adherence: Inquiries must be completed within the statutory 90-day window, followed by prompt implementation of IC recommendations.
Secure Record Keeping: All inquiry documentation and records must be stored securely with restricted access to ensure privacy.
Safe Work Environments: Management must actively maintain safe physical and digital workspaces free from hostility.
Annual Reporting: Submission of accurate annual compliance reports wherever mandated by local authorities.

Part E: SHe-Box Portal Onboarding

A vital addition in modern compliance governance is active digital integration through the SHe-Box portal:

Nodal Officer Appointment: Designate a specialized SHe-Box Nodal Officer for organizational oversight.
Portal Updates: Ensure that details of all office units, Nodal Officers, and Internal Committee structures are accurately uploaded and refreshed on the platform.
Digital Annual Filing: Upload mandatory annual compliance reports directly through the SHe-Box portal.

Why Every Employer Should Use This Checklist

The SHe-Box Compliance Checklist is an indispensable governance utility. Implementing it helps organizations:

Mitigate Legal Risks: Identify and remediate compliance gaps before they trigger litigation or regulatory penalties.
Empower the IC: Give your Internal Committee the clear benchmarks required to conduct fair, legally robust inquiries.
Build Employee Trust: Foster confidence that grievances will be handled with absolute transparency, safety, and discretion.
Prepare for Audits: Streamline readiness for external regulatory reviews or corporate governance evaluations.

Conclusion

POSH compliance is a continuous corporate commitment rather than a one-off task. From maintaining active policies and training IC members to utilizing digital platforms like SHe-Box, organizations must treat workplace safety as an evolving priority.

By proactively adopting the SHe-Box Voluntary Compliance Checklist, employers can drastically minimize legal exposure while fostering a culture grounded in trust, accountability, and respect.

SHe-Box Compliance Checklist: A Practical Guide for Employers to Stay POSH Compliant