POSH employer checklist

Map the workplaces and people

List offices, administrative units, work locations and the people engaged in the business. Assess coverage using the Act’s definitions rather than only the permanent payroll count. Consider work-related travel and other places connected with employment when preparing the policy.

For establishments with fewer than ten workers where an Internal Committee is not constituted, the Local Committee route applies; it also addresses complaints against the employer. Identify the relevant district contact so the route can be explained when needed.

Constitute a compliant Internal Committee

Where required, establish the committee by a written order and assess the arrangements for offices or administrative units at different places. Review membership eligibility, tenure and vacancies. A list of names without appointments and operational contact details is incomplete.

The statutory composition includes a senior woman employee as Presiding Officer, at least two employee members and an external member from the specified category; at least half the members must be women. Check the prescribed alternatives if a suitable senior woman employee is unavailable.

Make the system accessible

• Publish the policy and usable complaint contact details.
• Display the committee order and required information at the workplace.
• Explain available assistance for making a complaint.
• Provide accessible arrangements for people across locations and work patterns.
• Train managers to route concerns without deciding the merits themselves.
• Keep the Local Committee referral information available where relevant.

Train people for their roles

Organise employee awareness and committee orientation regularly. Keep dates, materials and attendance evidence, and provide new joiners with the policy and contact information. Committee members need preparation for fair procedure and confidentiality, not only general awareness.

For example, a manager who receives a concern should know how to connect the person with the appropriate process without circulating the account across a team chat. Practical routing instructions make the written policy usable.

Support a fair and confidential process

Provide the committee with facilities, information and assistance needed to carry out its functions. Keep case material restricted to authorised participants and follow the statutory confidentiality requirements. Protect the integrity of the process and avoid informal pressure on either party.

Maintain a case-specific timetable using the applicable complaint, inquiry, reporting and implementation provisions. Assess permitted extensions and other procedural choices on their facts rather than treating a generic calendar as a substitute for the Act.

Separate operational and case records

• Committee appointment orders, consent and tenure records.
• Policy versions, displays and employee communications.
• Awareness and orientation records.
• Restricted complaint and inquiry files with access controls.
• Recommendations and evidence of employer action.
• Annual reporting data and submission evidence.
• A record of vacancies, training needs and corrective actions.

Complete annual reporting and follow-up

Prepare the committee’s annual report and the employer’s required disclosures using accurate aggregate data. Confirm the applicable district submission process and current local instructions; do not publish confidential complaint details in general compliance reports.

Review whether contacts remain active, committee terms are current and recommendations have been addressed. Kosha.Services can help organise the policy, committee and annual evidence checklist. Use a secure channel for case-specific information rather than submitting sensitive narratives through a general enquiry form.