POSH Annual Report Generator (India)

About the POSH Annual Report Generator (India)

Under India’s Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, every Internal Committee must prepare an annual report for each calendar year and submit it to the employer and the District Officer (section 21), and the employer must report the number of cases filed and their disposal (section 22). Rule 14 of the Rules lists what the report contains: the complaints received in the year, the complaints disposed of, the cases pending for more than ninety days, the workshops and awareness programmes carried out, and the nature of action taken.

This generator writes those reports from the numbers you enter: one report per Internal Committee — one for every office or administrative unit — on your letterhead with the Committee’s members to sign, the employer’s consolidated report to the District Officer with a table by office, and the paragraph companies put in the Board’s report, from the financial year’s figures. It checks the numbers against each other, the Committee’s composition against section 4 and the remarks for anything that could identify the people involved.

Complaints are counted, never described: the reports carry no names, dates of incidents or details of any case (section 16). Nothing is uploaded. Without a pass the reports show as a free preview; a Premium pass unlocks the Word and PDF files and printing.

Common uses

• An HR team preparing the annual reports of several Internal Committees at the end of the calendar year.
• A company secretary writing the sexual-harassment paragraph of the Board’s report.
• An employer that needs a nil report for an office where no complaint was made.
• Consultants who prepare POSH compliance documents for client companies.

What the law asks for

• Section 21(1) of the Act: the Internal Committee shall in each calendar year prepare … an annual report and submit the same to the employer and the District Officer; under section 21(2) the District Officer forwards a brief report to the State Government.
• Section 22: the employer includes the number of cases filed, if any, and their disposal in its own annual report, or where no such report has to be prepared, intimates the number to the District Officer.
• Rule 14 of the Rules: the annual report has (a) the number of complaints of sexual harassment received in the year, (b) the number disposed of during the year, (c) the number of cases pending for more than ninety days, (d) the number of workshops or awareness programmes against sexual harassment carried out and (e) the nature of action taken by the employer or District Officer.
• Section 4(1): an Internal Committee at every office or administrative unit located at a different place — which is why each office gets its own report.

The Ministry of Women and Child Development publishes the Act, the Rules and its guidance on SHe-Box.

The documents

• Annual report of an Internal Committee: on the employer’s letterhead, addressed to the employer and the District Officer, with the Committee’s composition, the five rule 14 items, the complaints carried in and out of the year, how they ended, the action taken, interim relief, the workshops and your remarks, and signature spaces for the Presiding Officer and every member.
• Employer’s report to the District Officer: the totals under rule 14, a table by office or unit and the list of the Committees’ reports enclosed, signed by the authorised signatory.
• Board’s report paragraph (companies): the statement on the Internal Committee and the complaints received, disposed of and pending for more than ninety days in the financial year, ready to paste into the Directors’ report. Companies make this disclosure under rule 8(5) of the Companies (Accounts) Rules, 2014: check its current wording with the company secretary.

What the checks catch

• More complaints disposed of than were pending plus received, or more cases pending beyond ninety days than are pending at all.
• Ways of disposal that do not add up, and a year with complaints disposed of but no action stated.
• Inquiries beyond ninety days (s.11(4)) and a year without workshops or awareness programmes (s.19(c), rule 13).
• A Committee without a Presiding Officer, with fewer than two employee members or without the external member (s.4(2)), with fewer than half its members women, or older than the three-year term (s.4(3)).
• Remarks with an e-mail address, a phone number, an employee code, a calendar date or what looks like a person’s name.

Confidentiality

Section 16 forbids publishing or making known the contents of a complaint, the identity and addresses of the aggrieved woman, the respondent and witnesses, information about conciliation and inquiry proceedings, the Committee’s recommendations and the action taken. Rule 12 sets a penalty of five thousand rupees for a breach where no service rules apply. The reports therefore hold numbers and kinds of action only, and say so in a closing paragraph. With one or two complaints in a small office even the kind of action can point to someone: keep remarks general.

The time limits behind the numbers

• A complaint within three months of the incident (or the last of a series), which the Committee may extend by up to three months (s.9(1)).
• The inquiry completed within ninety days (s.11(4)) and its report within ten days after that (s.13(1)).
• The employer acts on the recommendation within sixty days (s.13(4)); an appeal within ninety days of the recommendations (s.18(2)).

Item (c) of rule 14 — cases pending for more than ninety days — is how the annual report shows inquiries that ran over.

Limitations

• A template prepared from the Central Act and Rules, not legal advice. A State Government or District Officer may ask for its own format or a date: check with your district.
• It makes the reports; it does not submit them. Print, sign and send them to the employer and the District Officer yourself.
• Counts only: there is no case-by-case register, by design (s.16).
• English only. The figures you enter are printed as you typed them.
• The first PDF or Word file needs a connection once, to load the document engine.

Privacy

Everything happens in your browser: the numbers and names you type are never uploaded. A draft is kept in this browser only if you tick “Keep a draft in this browser”; leave it off on a shared computer.