Best Practices and Steps for Implementing ICCs under the POSH Act - CiteHR

The Ernakulam District Collector in Kerala has issued a directive requiring all establishments with 10+ employees—government, semi-government, and private—to form Internal Complaints Committees (ICCs) under the POSH Act, 2013. The order includes mandates to report ICC member details, case logs, and outcomes through the state POSH portal, along with awareness campaigns and training.
The Times of India

This pushes POSH compliance out of selective zones into universal expectation. For staff without voice, it signals safety must be institutionalised, not optional. HR teams in small units previously ignoring ICCs will now be held accountable. The emotional effect may be mixed: some see overdue protection; others fear frivolous claims. How trust is built and transparency maintained will define impact.

Legally, this enforces obligations under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. HR must create ICCs with trained members, publish policies, conduct periodic training, record and report complaints, and ensure non-retaliation. Use of state POSH portals means audits will follow. Smaller establishments must find resource models (shared ICCs, rotating panels) to meet compliance without overburdening limited HR bandwidth.

If your unit had no ICC, what would be your first step to set one up?

How can HR ensure ICCs are functional and not just formal compliance?


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The first step to setting up an ICC in your unit would be to identify and appoint members who are committed to the cause of preventing sexual harassment at the workplace. The ICC should ideally be composed of a Presiding Officer (a woman employed at a senior level), not less than two members from amongst employees committed to the cause of women, and one member from a non-governmental organization or association committed to the cause of women or a person familiar with the issues relating to sexual harassment.

To ensure the ICC is functional and not just for formal compliance, HR can take the following steps:

1. Regular Training: Conduct regular training sessions for ICC members to ensure they understand the POSH Act, its implications, and their role in implementing it. This could include case studies, role plays, and discussions on various scenarios.

2. Awareness Campaigns: Organize awareness campaigns for all employees to ensure they are aware of the ICC, its role, and the process of lodging a complaint. This can be done through posters, emails, and interactive sessions.

3. Transparency: Maintain transparency in the functioning of the ICC. This includes sharing updates about the number of cases handled, without disclosing sensitive details, and actions taken to resolve them.

4. Accessibility: Ensure that the ICC is easily accessible to all employees. This could include having a dedicated email or phone line for complaints and queries.

5. Regular Audits: Conduct regular audits to ensure the ICC is functioning as per the guidelines of the POSH Act. This can help identify any gaps and take corrective action.

Remember, the goal is to create a safe and respectful workplace for all employees. The ICC is a crucial part of this and should be treated as more than just a compliance requirement.

From India, Gurugram
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