IT Company in Gurgaon — POSH Complaint Handling + External Member + Policy Redesign
The Client: An IT services company in Gurgaon with around 250 employees, serving national and international clients.
The Problem: A female employee filed a written POSH complaint with the HR Dept. against her reporting manager, alleging repeated inappropriate comments during team meetings and one-on-one calls over a period of six months.
The company's HR Dept. realized the following:
- The company's Internal Committee had no External Member (which made it legally non-compliant under the POSH Act, 2013).
- The existing POSH policy was a two-page document copied from the internet that didn't cover even half the required procedures.
- No employee in the company, including the IC members, had ever received formal POSH awareness training.
In short, the company had a live complaint on its hands and no legal framework to handle it properly.
What We Did as a POSH Consultant:
- We joined the Internal Committee as the External Member, without this, the committee cannot legally hear or handle any complaint.
- We explained the entire inquiry process to the Internal Committee step by step — from acknowledging the complaint within the statutory timeline, to conducting witness interviews, maintaining confidentiality, recording proceedings, and preparing the final inquiry report.
- We reviewed the existing POSH policy and redrafted a completely new one — explaining what counts as harassment, how to complain, the procedure, penalties, and relief.
- We conducted four POSH awareness training sessions — three for all 250 employees explaining what POSH is and how to report a problem, and one for IC members teaching them how to conduct inquiries, handle evidence, maintain confidentiality, and write findings.
- We reviewed and updated the company's employee handbook to include the new POSH policy, complaint process, and IC member details.
- We set up a confidential complaint submission channel for employees (dedicated email + physical drop box) so future complaints could be filed safely without going through the accused person's reporting chain.
Final Result: The inquiry was completed within the 90-day deadline required by law. The IC found that the complaint was genuine, and the company took disciplinary action against the manager based on the IC's recommendation. No appeal was filed. The company is now fully POSH-compliant with a trained IC, a detailed policy, and annual refresher training scheduled under the POSH retainership. Most importantly, the woman who complained felt heard, protected, and supported throughout the process — which is exactly what the POSH Act was created for.
