Section 19 of the POSH Act, 2013 requires every employer to display a written POSH policy at the workplace. But the law does not specify a template — and as a result, many organisations have policies that are legally incomplete, outdated, or simply copied from the internet without adaptation.
A POSH policy is a live legal document. It must name your IC, describe the complaint process, state the employer's commitment, and be accessible to every employee. FIO Foundation drafts and reviews POSH policies for Kerala organisations of all sizes.
What Must a POSH Policy Include?
While the POSH Act does not prescribe a specific format, legal practice and court interpretation establish that a compliant POSH policy should include:
- Statement of commitment — the employer's clear statement that sexual harassment will not be tolerated
- Definition of sexual harassment — aligned with the Act's definition in Section 2(n), covering all five categories and both forms (quid pro quo and hostile environment)
- Scope — who the policy applies to, including employees, contractors, clients, visitors, and trainees
- Internal Committee details — the names and contact details of IC members (which must be updated on reconstitution)
- Complaint process — how to file a written complaint, the 3-month limitation period, and the right to request conciliation
- Inquiry process overview — the complainant and respondent's rights during the inquiry, confidentiality obligations, and the 90-day inquiry timeline
- Consequences — what disciplinary action may follow a substantiated complaint
- Protection from false complaints — the Act provides for action against false complaints under Section 14, but no monetary settlement shall be the basis of conciliation
- Non-retaliation commitment — protection for complainants from victimisation
Common Policy Gaps We Find
- Policy names an IC but the members named are outdated or have left the organisation
- Policy does not describe the complaint process clearly
- Policy is only in English when the workforce is predominantly Malayalam-speaking
- Policy does not mention the 3-month limitation period
- Policy refers to a "Complaints Committee" but does not describe how to access it
- Policy has no employer signature or date — making it unenforceable
What FIO Foundation Provides
Policy Review
We review your existing POSH policy document against current legal requirements and provide a written assessment of gaps.
Policy Redraft
We draft a new, legally compliant POSH policy customised to your organisation — in English, Malayalam, or bilingual format.
Display Compliance
Guidance on how to display the policy at your workplace to meet the Act's requirements.
Annual Update Service
Annual review to update IC member names on reconstitution and verify policy currency.
Related POSH Services in Kerala
POSH Employee Awareness Training
Activity-based sessions for all employees in Malayalam or English. Half-day or full-day. Certificate of Participation issued.
Learn more →IC Formation & Training
Legally compliant IC setup under Section 4 of the POSH Act — appointment order, member selection, full training for Presiding Officer and members.
Learn more →External Member Services
FIO Foundation can serve as your IC's external member with year-round helpline access and inquiry support.
Learn more →POSH Compliance Audit
A thorough review of IC constitution, POSH policy, training records and Annual Report history — with a written gap report and remediation roadmap.
Learn more →POSH Policy Review & Drafting
We review or redraft your POSH policy to meet current legal requirements — English, Malayalam or bilingual.
Learn more →POSH Helpline & Case Advisory
Kerala's dedicated POSH helpline for IC members, HR teams and employers — process guidance whenever you need it.
Learn more →Frequently Asked Questions
Can we just use a template from the internet?+
Templates can be a starting point but should never be your final policy. The policy must name your actual IC, describe your specific complaint process, and be signed and dated by the employer. Generic templates often miss critical legal elements and create false confidence.
Should the policy be bilingual?+
If a significant portion of your workforce communicates primarily in Malayalam, yes. The policy must be genuinely accessible to every employee, which means available in a language they can read.
How often should the POSH policy be updated?+
Review annually, and always immediately on IC reconstitution. IC member names and contact details must be current; otherwise the complaint route described in the policy fails.
Does the policy need to be displayed at the workplace?+
Yes. The policy, along with information on what constitutes sexual harassment and the consequences, must be displayed at a visible location.
Can FIO Foundation draft a policy for a small organisation?+
Yes. We work with organisations of every size. The policy still has to meet the legal essentials regardless of headcount.
Request a POSH Policy Review
Kerala's POSH Act specialists. Call us, WhatsApp us, or write to us.