In a country like India, where female labour force participation remains among the lowest in the world—hovering around 25% according to recent estimates—it is not uncommon for certain workplaces to have few or no women employees. This is especially true for sectors such as manufacturing, logistics, and heavy industries, where the workforce is often predominantly male.
However, even in such cases, compliance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (PoSH Act) is non-negotiable. The law requires every organisation with 10 or more employees to constitute an Internal Committee (IC) to address complaints of sexual harassment at work. The absence of women in the workforce does not exempt a company from this legal obligation.
The challenge, then, is how to structure a PoSH IC that meets both the letter and the spirit of the law when gender representation is limited.
Nominating a presiding officer
As per Section 4(2)(a) of the PoSH Act, the Presiding Officer of every Internal Committee must be a woman employed at a senior level at the workplace. But when a company has no women employees, this becomes complicated.
In such situations, the Act allows for flexibility. The employer may nominate a woman employee from another branch, division, or administrative unit of the same organisation to serve as the Presiding Officer. This ensures that the IC still complies with gender representation norms while maintaining organisational consistency.
For example, a manufacturing plant in a remote location may not have any women employees on-site, but it can nominate a senior woman professional from its head office or regional office. The key is to ensure that the person chosen is empowered, aware of workplace policies, and has the authority to handle complaints with confidentiality and fairness.
This approach not only fulfils compliance requirements but also signals to employees that the organisation values fairness and safety, regardless of workforce composition.
Nominating an external member
The external member plays a crucial role in ensuring impartiality and credibility within the Internal Committee. As per the PoSH Act, this member must be someone who is either:
- Associated with an NGO or association committed to the cause of women, or
- Familiar with issues related to sexual harassment at the workplace.
In all-male workplaces, the external member can also help balance gender representation within the IC. The law mandates that at least 50% of the IC’s members must be women, so the external member’s gender can make a significant difference.
Organisations often engage lawyers, social workers, or DEI professionals with expertise in PoSH compliance to serve in this role. Having a woman external member not only satisfies statutory requirements but also brings a valuable perspective and sensitivity to the proceedings.
This external oversight is particularly important in male-dominated industries where cultural norms might discourage reporting or where gendered experiences are less visible in daily operations.
Examples of all-male companies with PoSH ICs
Several Indian organisations have already implemented thoughtful workarounds to ensure compliance even in male-heavy environments.
TATA Power operates multiple Internal Committees, such as those in Noida and Delhi (SED Division), with representation drawn from other branches to ensure balanced composition.
Nestlé India has adopted a cross-location model, where the Presiding Officer from Delhi also serves on the Gurgaon IC to maintain compliance and consistency.
CIS India has designated the same Presiding Officer for its Delhi and Bangalore offices to ensure uniformity in handling cases and training.
Godrej & Boyce, along with Café Coffee Day, have similarly structured their ICs to ensure the presence of women members from other locations when local representation is limited.
These examples demonstrate that compliance is achievable through proactive planning and collaboration across units.
Beyond Compliance: Building Safer Workplaces
Setting up an IC is not merely a procedural requirement—it’s a commitment to culture. When women are absent from the workforce, it becomes even more critical for employers to create visible systems of trust and accountability.
Companies should:
- Document the IC’s composition clearly, specifying from which branches members have been nominated.
- Conduct PoSH training sessions that reach every employee, including contract and field staff.
- Review and update policies regularly to reflect structural or workforce changes.
- Ensure confidentiality and sensitivity, especially when complaints arise in small or closely knit teams.
While the law prescribes structure, culture defines practice. When employees—regardless of gender—see that safety mechanisms are in place, it encourages trust, transparency, and compliance.
The PoSH Act was never meant to be a checkbox exercise. It’s a reminder that safety is not dependent on numbers, but on intent. Even in workplaces without women, there is still a responsibility to build environments where respect, fairness, and accountability are non-negotiable.
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References
https://www.tatapower.com/pdf/aboutus/Sexual-harass-policy.pdfhttps://www.nestle.in/sites/g/files/pydnoa451/files/investors/documents/policiescodeofconduct/prevention-of-sexual-harassment-%28posh%29-of-women-at-workplace.pdf