Dear CiteHR member Ms Chaitali,
Greetings!
I would slightly differ from the comments of Ms P. Lekha Jacob. You have written your company has PAN India existence, so it is different from PAN India operations. PAN India existence denotes that you have branch/administrative offices almost in all the states of India. If it is so, as you have written, then please note the following:
1. Section 4(1) of the SHWW (PPR) Act 2013 lays down that where the offices or administrative units are located at different places, the IC (Internal Committee) shall be constituted at all administrative units/offices. In addition to this you have to constitute a POSH Committee i.e. IC for the Head Office separately.
2. A company has to have only one POSH Policy for all its offices which is compliant to the provisions of SHWW (PPR) Act 2013.
3. Every IC must have an independent non-official member as provided in Section 4(2)(c) of the Act. Such a member can be from an NGO/Association or a person familiar with the issues related to sexual harassment. Thus it is not necessary that you should always look for a NGO member. Some NGO members attempt to rule the IC which is not in accordance with the spirit of the Act and Rules. The Role of NGO Member is to oversee the proceedings of IC and ensure that no unfair treatment or pressure is exercised on either party i.e. the aggrieved woman the the respondent man.
Comments of Ms Sudha are about creating awareness about the Act and IC among the employees which can be taken up separately.
Hope this will help you understand more clearly the concept of POSH committees and roles of members.
With due regards to Ms P. Lekha Jacob and Ms Sudha and with all good wishes,
Chandra Mani Lal Srivastava
Master Consultant 931551603
POSH Committee Member & Subject Expert
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New Delhi
19.01.2022/9:26 pm