This communication has been issued by the Additional Deputy Commissioner, Gurugram-cum-District Officer under the PoSH Act, 2013, addressed to all non-government organisations (including schools, banks, and companies) operating in Gurugram. It reiterates that constitution of an Internal Committee (IC) and compliance with all provisions of the PoSH Act are statutory obligations. Organisations are directed to submit a comprehensive compliance checklist along with the Annual Report of the Internal Committee for the period from January 1, 2025 to December 31, 2025.

• Organisations must confirm that an Internal PoSH Policy for prevention, prohibition, and redressal of sexual harassment has been prepared and implemented, and provide the reference number of such policy.
• Employers must state whether sexual harassment is recognised as misconduct under service rules, employment contracts, or standing orders, and disclose the relevant reference.
• Confirmation is required on constitution of the Internal Committee at the workplace as mandated under the PoSH Act, 2013, including constitution at all administrative units where offices are located at different places.
• Employers must confirm that PoSH-related notices are displayed at conspicuous places in the workplace, informing employees about organisational stance and consequences of sexual harassment, along with sample copies and display locations.
• Details of display of Internal Committee member information in English and regional languages must be provided, ensuring accessibility to employees, vendors, contract labour, and other support staff.
• Organisations must disclose details of employee awareness programmes conducted during calendar year 2025, including:
  • Number and dates of physical (in-person) orientation programmes
  • Number and dates of virtual orientation programmes
  • Instructor-led virtual programmes
  • E-learning modules and languages in which they were disseminated
• Employers must confirm that all categories of workers, including contractual staff such as security guards, drivers, loaders, and housekeeping staff, were covered under awareness programmes.
• Information must be provided on systems or processes in place to assist aggrieved women in approaching the Internal Committee and in addressing psychological or other effects of sexual harassment.
• Employers must confirm whether assistance is provided to aggrieved women for filing criminal complaints under the Indian Penal Code or other applicable laws.
• Detailed particulars of the Internal Committee must be furnished, including:
  • Presiding Officer (senior-level woman employee)
  • Internal members
  • External member qualified under the PoSH Act, 2013
  • Official designation and contact details of each member
• Employers must confirm whether orientation and capacity-building programmes for Internal Committee members were conducted, along with dates and year-wise details for 2024 and 2025.
• Confirmation is required on whether adequate facilities are provided to the Internal Committee for conducting sexual harassment inquiries.
• Employers must confirm compliance with interim and final recommendations of the Internal Committee or Local Committee, as applicable, within prescribed timelines.
• Monitoring of functioning and performance of the Internal Committee must be confirmed, including adherence to timelines, procedures, and consideration of conciliation and interim measures.
• Organisations must submit the Annual Report of the Internal Committee under Section 21 of the PoSH Act, containing:
  • Number of sexual harassment complaints received during the year
  • Number of complaints disposed of during the year
  • Number of complaints pending for more than ninety days with reasons
  • Number of workshops or awareness programmes conducted
  • Nature of action taken by employer or District Officer
• Companies must confirm disclosure of PoSH compliance in the Directors’ Report as required under Rule 8 of the Companies (Accounts) Rules, 2014.