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POSH Compliance Module

What Is This Module For?

The POSH module helps you comply with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act) — tracking your Internal Complaints Committee (ICC), complaints, and mandatory annual reporting.

Which Law Requires This?

  • POSH Act 2013, Section 4 — Every employer with 10 or more employees must constitute an Internal Complaints Committee (ICC).
  • POSH Act 2013, Section 21 — The ICC must submit an Annual Report to the employer and the District Officer before 31st January each year.
  • POSH Act 2013, Section 26 — Non-compliance can attract penalties up to ₹50,000 and cancellation of licence/registration.

Step-by-Step Guide

  1. Go to POSH in the sidebar.
  2. Record your ICC members — Presiding Officer, two employee members, and one external member (NGO/lawyer). Tenure is 3 years.
  3. Log any complaints received — with complaint date, respondent details, and ICC proceedings (maintaining strict confidentiality).
  4. Record complaint outcomes — resolved, dismissed, or referred to police.
  5. Generate the Annual Report by 31st January — dcomply pre-fills the Section 21 report format with your ICC details and complaint statistics (without identifying individuals).

Common Mistakes to Avoid

  • Not including an external member on the ICC — The external member (from an NGO or legal background) is mandatory under Section 4(2)(c).
  • Missing the 31st January Annual Report deadline — Non-submission is a POSH Act violation.
  • Including employee names in the annual report — The annual report must contain only statistics, not identifying information.

Frequently Asked Questions

Q: What if no complaints were received in the year?
A: You still must submit the Annual Report stating zero complaints. Non-submission is an offence regardless.


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