Frequency of Internal complaints committee meetings as per POSHA

Dear Fellow Members and Seniors,

I have a query on the frequency of Internal Complaints Committee meetings required in an organization. I have perused the relevant Act (The Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013) and found that there is no specific provision regarding the frequency to conduct ICC meetings. When we have complaints by an aggrieved woman, the frequency of meetings is different as proceedings start on a cause of action.

But my question is, in the absence of any complaints/issues by any women employees, what would be the minimum prescribed number of ICC meetings in a company? What is more ideal?

NB: We conduct seminars, workshops, and awareness classes related to the Prevention of sexual harassment and also file an Annual report to the Authority in an orderly manner.

Dear Opinion-Seeker,

Kritarth Team's Stand:

First things first, the nomenclature/name of the independent legal entity constituted under Section-4 of the "Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act 2013 is Internal Committee for Employers Organization.

Now, regarding the frequency or regularity or interval of meetings of the IC, every employer (read management team) needs to carefully go through the text of the Preamble as well as that of Section-19 (Duties of Employer) of the aforementioned Act of 2013 and realize that it is the employer's enforceable duty to "Provide protection to women from sexual harassment at the workplace (arising out of and in the course of employment) by creating a safe and secure workplace where no woman is subjected to sexual harassment. Towards achieving that objective, it becomes expedient/essential to seek and secure cooperation, rather collaboration between the IC members and all employees & others at the workplace.

The IC thus can/must serve as the body/forum spearheading the movement, as it were, not just a campaign as at least 3 out of minimum 4 members are nominated from amongst employees. As a serving IC member (external) on several ICs, our team prevails over/convince why the IC in their establishments ought to convene its meeting once every quarter, to begin with, and spread the message that:
1. Sexual harassment amounts to and is treated as a violation of the fundamental right (Article 14, 19, 21, etc., of the Indian Constitution as stipulated in the preamble;
2. SH also amounts to a breach of service rules/standing orders as applicable to the respective establishment;
3. SH attracts IPC Section-354, 377, and others applicable as it amounts to outraging the modesty of women. Let your members deliberate and themselves decide the frequency of their IC review meeting and circulate the minutes of their meetings for information employees & others concerned. Increased awareness leads to attaining the objective with which the Act of 2013 was added to pre-existing employment-related laws.

Requests for guidance/assistance welcome.

Kritarth Team of Spl Educators, PoSH Programs
11th July 2018