The PoSH Act- Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) 2013 was enacted to protect women from sexual harassment and provide a safe and secure work environment.

Is poSH training mandatory?

Creating awareness among the employees about the prevention of sexual harassment of women is mandated by the PoSH Act. That makes PoSH training mandatory.

ICC—The Internal Complaints Committee (now called the Internal Committee/IC) was introduced as a feature by the PoSH Act 2013. Every organization should have an ICC that registers complaints and investigates them fairly.

What is the object of PoSH?

Prevention of Sexual Harassment (PoSH) aims to create an organization's safe, secure, harassment-free work environment.

What are examples of harassment?

Harassment can be in any form. An example of sexual harassment is when a person in a managerial position offers job benefits to a female employee in exchange for sexual favours.

Why is PoSH training essential?

PoSH training is essential to raise awareness among workplace employees and help create a safe and secure work environment for women.

What is the origin of PoSH Law in India?

The PoSH Law 2013 is the first legislation passed in India specifically to protect women in the workplace from sexual harassment.

What is PoSH awareness?

The PoSH awareness course explains the PoSH Act 2013 and what constitutes sexual harassment. It promotes awareness to prevent harassment of women at work.

A law to protect and prevent harassment of women in the workplace and redress the registered complaints.

What defines harassment?

Harassment comprises offensive behaviour that has the potential to adversely impact one’s emotional and physical well-being, productivity, and relationships, which could result in a toxic workplace environment.

Why is PoSH important?

The PoSH Act is essential for protecting women from sexual harassment in the workplace. It creates a safe and secure work environment and acts as a saviour for women.

Who can file a complaint of sexual harassment in the workplace?

According to the PoSH Act, any woman working in or visiting a workplace for employment can file a complaint. She can work as a permanent, temporary, or ad-hoc employee or on a daily wage, voluntary, or contract basis. Visitors, probationers, trainees, apprentices, and interns can file complaints.

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Does Every Project Site Need an Internal Committee Under the PoSH Act? Understanding Administrative Units

An organisation operates a corporate office alongside ten project sites across India. Does it require a single Internal Committee under the PoSH Act at the head office, or should an Internal Committee (IC) be constituted at every individual project site?

Determining the right setup for Internal Committee constitution should not begin with counting physical locations. Instead, it starts with a fundamental operational question: Does each location function as a separate office or administrative unit?

Structuring your Internal Committee under the PoSH Act correctly ensures total regulatory compliance and builds an accessible, fair redressal mechanism for your entire workforce.

What Does the PoSH Act Say About IC Constitution?

Section 4(1) of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 mandates that every covered employer constitute an Internal Committee (IC).

Importantly, the proviso to Section 4(1) specifies that where offices or administrative units of a workplace are located at different places, or at divisional or sub-divisional levels, an IC must be constituted at all such administrative units or offices.

This requirement makes organizational hierarchy pivotal when determining Internal Committee constitution requirements. However, because the law does not explicitly define what constitutes an "administrative unit," organisations often make simplistic assumptions:

"Every physical project site automatically requires its own IC."
"One central IC at the head office automatically covers every remote location."

Neither assumption thoroughly evaluates how administrative units under the PoSH Act actually operate in practice.

Indicators of Administrative Units Under the PoSH Act

To determine the appropriate Internal Committee structure, organisations should assess whether a specific site possesses an identifiable structure for management, supervision, control, or daily administration.

Key indicators that help identify administrative units under the PoSH Act include:

Employees regularly stationed at the location
A designated Site Head, Project Manager, or local reporting authority
Local supervision and allocation of daily work
Attendance, leave, or workforce management handled on-site
Dedicated HR or administrative support
Maintenance of employee records and operational logs
Local authority to make routine operational decisions
Formal designation as a branch, project office, regional office, plant, or unit

No single factor acts as an absolute rule. The overall factual matrix and reporting hierarchy must be evaluated together.

Assessing Project Sites: Two Practical Examples

Project Site A

This location has 80 employees, a dedicated Project Head, site administrators, supervisors, and a permanent office setup. These characteristics strongly support classifying it as a distinct administrative unit requiring its own Internal Committee under the PoSH Act.

Project Site B

Four employees periodically work out of a client’s premises. They report directly to the head office, and there is no local manager, HR presence, or independent administration.

While Site B falls under the broad definition of a "workplace," it may not necessarily qualify as an independent administrative unit. It is essential not to confuse the general concept of a workplace under the PoSH act with designated administrative units.

Don't Rely on Employee Count Alone

A common mistake when assessing Internal Committee requirements is assuming that locations with fewer than 10 employees can skip administrative analysis altogether.

While headcounts matter for overall applicability, determining whether geographically separate locations qualify as administrative units under the PoSH Act requires a detailed review of your management and administrative control structures.

How to Map Your Internal Committee Structure

Before constituting your Internal Committee (IC), multi-location organisations should conduct a formal IC Jurisdiction and Administrative Unit Mapping Exercise:

Map the Network: Trace your organization hierarchy across Head Office, Regional Offices, Branches, Plants, Warehouses, Project Sites, and Client Locations.
Evaluate Administrative Control: Assess local management authority and administrative independence for each node.
Document the Rationale: Record clear, documented justifications for the IC structure chosen across all sites.

Organisations can also refer to SHTC's PoSH Compliance Audit Checklist when reviewing committee documentation.

Once the IC structure is mapped, organisations can strengthen committee capabilities through IC Members Training.

The objective is not merely to create additional committees. It is to build an IC structure whose jurisdiction, accessibility, and operational scope accurately reflect how your workforce operates daily.

For multi-location enterprises, the core compliance question is simple: How many of our locations function as separate offices or administrative units—and does our IC structure appropriately reflect them?

Frequently Asked Questions

1. What is an "administrative unit" under the PoSH Act?

An "administrative unit" refers to a branch, division, or operational site that possesses its own management, supervisory control, or administrative framework. Although the Act does not explicitly define the term, operational features such as local reporting authorities, independent record-keeping, and site-level supervision indicate an administrative unit.

2. What factors help decide whether a project site is an administrative unit?

Key factors include the presence of a site head or local reporting manager, dedicated HR or administrative support, on-site attendance management, operational record maintenance, and local decision-making authority.

3. Does every project site need a separate Internal Committee under the PoSH Act?

Not necessarily. A project site requires a separate Internal Committee under the PoSH Act if it functions as an independent office or administrative unit. Sites lacking local administrative control or reporting structures may fall under the jurisdiction of a regional or central IC.

4. How should multi-location organisations assess their Internal Committee structure?

Multi-location organisations should conduct a mapping exercise across all branches, project sites, and client locations. By assessing the administrative structure and reporting lines at each location, organisations can document a clear rationale for their IC jurisdiction and constitution.

Review Your Internal Committee Structure

Structuring your Internal Committee (IC) across multiple locations requires careful alignment with legal benchmarks and operational realities.

Need expert guidance on mapping your IC jurisdiction or streamlining Internal Committee processes across your organization?

For organisations requiring independent committee support, explore SHTC's External IC Membership Support.

Visit SHTC or reach out to our legal and HR compliance specialists to audit and structure your Internal Committee framework today.

Disclaimer: This article is intended for general awareness and should not be treated as legal advice. Organisations should evaluate their specific structure and applicable legal requirements before determining their IC constitution.

Author: Ankur Gohri, Director SHTC (www.shtc.co.in)