When the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, commonly known as the PoSH Act, was first implemented, many organisations viewed it primarily as a mechanism for redressal. The focus often rested on responding to complaints, conducting inquiries, and ensuring procedural compliance. However, the lawmakers soon clarified that the true intent of the PoSH Act extends far beyond redressal.
The Act is not only about responding to instances of sexual harassment but also about preventing and prohibiting such conduct in the first place. This legislative intent underscores the proactive responsibility of employers and Internal Committees (ICs) alike: to foster awareness, encourage dialogue, and create systems that deter harassment before it occurs.
By emphasising prevention and prohibition, the Act envisions a workplace that is not just reactive but culturally aware and ethically grounded. Employers are expected to cultivate sensitivity, train their workforce, and make employees aware of both their rights and responsibilities under the law. The IC, in turn, acts as both a guardian and an educator, ensuring that employees know where to seek help and how to recognise unacceptable behaviour.
IC Meetings: A Good Practice
With this preventive intent in mind, it is considered a good practice for the IC to convene at regular intervals, even when no complaints are pending. Regular meetings strengthen the committee’s efficiency and ensure that its members remain aligned with their responsibilities.
These meetings serve several important purposes. They allow the IC to:
- Review ongoing workplace practices and assess whether the existing systems support a safe work culture.
- Evaluate the effectiveness of awareness and sensitisation sessions.
- Identify any gaps in communication or training related to the PoSH policy
- Discuss emerging issues that could lead to misunderstandings or potential risks if left unaddressed.
For instance, an IC might use these meetings to review the accessibility of complaint channels, ensure that posters with IC details are displayed at all office locations, or plan an upcoming awareness session. Such proactive engagement helps the organisation stay ahead of compliance requirements while reinforcing trust and transparency within the workforce.
Beyond administrative diligence, these meetings are a space for reflection and calibration. They enable IC members to discuss complex cases they may have encountered, learn from other organisations’ best practices, or consult external members for guidance on evolving interpretations of the law. The goal is to maintain preparedness and consistency — two key factors in ensuring that any future complaint is handled with fairness and competence.
What the PoSH Act Says About IC Meetings
Interestingly, the PoSH Act does not prescribe a rigid format or frequency for IC meetings. This flexibility allows organisations to design schedules and processes that best fit their size, structure, and mode of operation.
Meetings may be held physically, virtually, or in hybrid formats, depending on the convenience and location of the members. This inclusivity is particularly useful for large organisations spread across multiple cities or for those operating in hybrid work environments. For example, an IC member on official travel can still join the deliberations through video or audio conferencing and contribute meaningfully to the discussion.
The law also recognises that full attendance may not always be feasible. What is essential is that the minimum quorum, as defined by the organisation’s policy, is met to validate the meeting’s proceedings. This ensures that discussions and decisions are legally sound without being hindered by logistical challenges.
In addition, every meeting should be documented through minutes or a written record, outlining key discussions, decisions, and future action items. These records serve as valuable evidence of the IC’s active functioning and commitment to its statutory duties. They may also be reviewed during audits or inspections by authorities to confirm compliance.
Why Regular Meetings Matter
Regular IC meetings, even in the absence of complaints, are not merely procedural, they are preventive safeguards. They communicate to employees that the organisation takes its commitment to safety and equality seriously. When employees see that the IC is active, accessible, and engaged, it builds confidence in the redressal mechanism and encourages individuals to speak up without fear.
Furthermore, such meetings enable the IC to stay updated on emerging workplace trends — such as virtual harassment, evolving gender dynamics, or new technology-related risks. By staying informed, the IC can adapt its guidance and awareness sessions to address these realities, ensuring that the workplace remains a safe space in both physical and digital contexts.
These meetings also provide an opportunity to evaluate the organisation’s preventive programs. The IC can assess whether training materials are relevant, whether managers are adequately equipped to handle complaints, and whether communication around the PoSH policy reaches all levels of staff, including remote or contractual workers.
Building a Culture of Prevention
Ultimately, the spirit of the PoSH Act lies not in compliance alone, but in creating a culture of respect and accountability. Prevention requires continuous engagement — from leadership commitment to policy reinforcement, awareness sessions, and regular communication about rights and redressal processes.
By adopting regular IC meetings as a standard practice, organisations move closer to embodying this spirit. These meetings become a symbol of ongoing vigilance and ethical responsibility — a reminder that workplace safety is not a one-time effort but a continuous, evolving process.
Conclusion
While the PoSH Act mandates that the Internal Committee must convene upon receipt of a complaint, the spirit of the law encourages a far more proactive stance. Regular IC meetings, even in the absence of complaints, reflect an organisation’s dedication to prevention, learning, and the continuous improvement of its workplace culture.
By institutionalising such practices, companies not only comply with the letter of the law but also embody its deeper intent, to ensure that every employee, irrespective of gender or role, can work in an environment of safety, dignity, and mutual respect.
We at Serein help you IC put in place strong and legal foundation. Reach out to us at hello@serein.inc.