PoSH Compliance Survey Directive & Responsibilities of Employers

[NIRATHANKA]

Dear All,
We are sharing an important Government of Karnataka circular (dated 21 August 2025) regarding a mandatory compliance directive under the POSH (Sexual Harassment of Women at Workplace) Act, 2013.

Key Highlights from the Circular:
1. Mandatory Formation of Internal Complaints Committee (ICC)
Every employer must ensure the constitution of an ICC. If your organization has not yet formed this   committee, you are required to take immediate action as per the POSH Act provisions.
 
2. Survey and Data Collection Directive
A survey — directed vide the order dated 3 December 2024 — must be conducted within *six weeks* from the date of the circular (i.e., by early October 2025). This exercise, overseen by District Labour Commissioners and the Chief Labour Commissioner of the State, aims to verify the constitution of ICCs across workplaces.

3. Labour Department Oversight
The Labour Department holds the responsibility to confirm whether every employer has complied by forming an ICC and to take corrective actions where deficiencies are identified.

Action Items for Employers:
Immediate ICC Setup: If not already established, form your ICC immediately to comply with Section 4 of the POSH Act.
Submit Survey Data: Coordinate with your local District Labour Commissioner or Chief Labour Commissioner to ensure your organization’s compliance status is accurately reported.
Maintain Documentation: Keep evidence of the ICC constitution — including committee constitution letter, member details, and related minutes of meetings or communications.

Supreme Court of India directed  a district-wide survey across all Government and private institutions to verify ICC establishment and POSH compliance .
This directive is time-sensitive. It is not merely a formality but a crucial step in ensuring workplace safety and legal compliance. Let us proactively act to form, document, and report our ICC constitutions — fostering safer work environments for all.

Nirathanka has been helping organisations with expert external members for ICCs since 2016, If you would like professional assistance with any of the following, please feel free to reach out:

* Deputing qualified external members  to serve on your ICC
* Drafting or finalising ICC formation documentation
* Conducting POSH awareness sessions and training
* Navigating the overall POSH compliance process

For more details please visit: https://www.niratanka.org/posh-service.html

Mob: 8088433026, 8073067542
Email: hrnir...@mhrspl.com

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Regards,

Rakesh R

Manager

NIRATHANKA

#1495, Sir M Vishweshwaraiah Layout, 7th Block,

Upkar Layout, near Ullal RTO Office, Bengaluru 560091

 www.niratanka.org

 PH: 8088433026 / 8073067542 

Nirathanka is a non-governmental organization with its registered office at Bangalore. Formed in 2007, its primary objective was to extend services to the elderly men and women in Karnataka. Subsequently, Nirathanka has spread its areas of service to diverse social sector fields such as education, health care, food security, and livelihood training.

Vision
Creation of a knowledge society in Karnataka and in the entire country for ushering in social justice and equity.