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Every employer shall — organise workshops and awareness programmes at regular intervals for sensitising the employees with the provisions of the Act and orientation programmes for the members of the Internal Committee in the manner as may be prescribed.
Section 19(c), POSH Act 2013Read the clause slowly and it separates into two commitments with different audiences. Workshops and awareness programmes are for the employees, at regular intervals. Orientation programmes are for the members of the Internal Committee. A company that circulates an annual e-learning module to all staff and has never sat its Committee down has performed one half of the clause.
The gap matters because of who bears the consequence. When an inquiry is later challenged, it is not the staff deck that is examined. It is whether the Committee understood that conciliation under Section 10 can only follow the aggrieved woman's request and can never rest on a monetary settlement; whether it knew the inquiry had to close within ninety days under Section 11(4); whether the report went out within ten days under Section 13(1); and whether it appreciated the proviso to Section 14, that a mere inability to substantiate a complaint does not by itself justify action against the complainant.
Section 19(b) is a third and separate duty that is often collapsed into training: display at a conspicuous place in the workplace of the penal consequences of sexual harassment and of the order constituting the Internal Committee under Section 4(1). It is a per-workplace obligation, discharged by a notice board and not by a session.
The Section 19(c) employee limb. What the Act prohibits under Section 2(n), the circumstances in Section 3(2), who is covered under Section 2(f) and where under Section 2(o), how to complain under Section 9 and the three-month limit, and what confidentiality under Section 16 means for anyone who hears about a matter. Run in the language of the site where that matters.
The Section 19(c) Committee limb, run separately. Constituting validly under Section 4(2), conducting an inquiry inside ninety days under Section 11(4), interim relief under Section 12, writing a report that survives scrutiny under Section 13, determining compensation under Section 15, and applying Section 14 on false or malicious complaints with the care its proviso requires.
For the people who receive a disclosure before the Committee does. Recognising the Section 3(2) circumstances in a reporting line, what a manager must not do on hearing a complaint, the employer duties in Section 19 that managers actually discharge in practice, and the retaliation exposure that sits behind them.
Coverage between annual cycles, so that the "regular intervals" claim in Section 19(c) holds for a workforce that changes through the year. Short, recorded, and tied to the policy and the Section 19(b) display at the joiner’s own site.
Section 2(n) defines sexual harassment as including any one or more of five unwelcome acts or behaviours, whether directly or by implication. Section 3(2) then sets out five circumstances which, among others, may amount to sexual harassment if they occur in relation to or connected with any act or behaviour of sexual harassment. Training that covers only the first list, as most imported global modules do, leaves out the part that employees in Indian workplaces most often experience.
The two lists work together. Section 3(1) states the underlying prohibition plainly: no woman shall be subjected to sexual harassment at any workplace.
Section 2(f) defines an employee as a person employed at a workplace for any work on regular, temporary, ad hoc or daily wage basis, either directly or through an agent including a contractor, with or without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, and whether the terms of employment are express or implied. It expressly includes a co-worker, contract worker, probationer, trainee and apprentice.
The practical consequence is that a training cycle scoped to the HRMS headcount will usually miss the facilities, security, transport, catering and agency populations that share the same floor, along with interns and consultants. Those people are inside the Act. Section 2(o) defines workplace expansively as well, reaching private sector organisations, enterprises, institutions, societies, trusts and service providers carrying on commercial, professional, vocational, educational and other activity.
Where a company has offices at more than one place, the training plan follows the same map as the committees: the proviso to Section 4(1) requires an Internal Committee at all administrative units or offices, and the orientation limb of Section 19(c) then applies to each of them. That mapping exercise is set out on the POSH compliance page.
A duty performed but not recorded is difficult to defend. Section 25 empowers the appropriate Government, where it is satisfied that it is necessary in the public interest or in the interest of women employees, to call upon an employer to furnish information and to inspect records. Section 26(1) makes contravention of the provisions of the Act punishable with fine which may extend to fifty thousand rupees, with the heavier consequences of Section 26(2) on a subsequent conviction.
We leave an employer with dated attendance records for each session, the material used, separate evidence of the Committee orientation as distinct from the staff workshops, and induction coverage for joiners through the year. That file is what makes the phrase “at regular intervals” a demonstrated fact rather than an assertion, and it feeds directly into the annual reporting under Sections 21 and 22.
Where a company would rather hold training, committee seats and the rest of its recurring legal work under one standing arrangement, the fractional general counsel model covers it. Companies looking specifically to fill a committee seat should see the external member page.
Yes, and it is two obligations rather than one. Section 19(c) of the POSH Act 2013 requires every employer to organise workshops and awareness programmes at regular intervals for sensitising the employees with the provisions of the Act, and orientation programmes for the members of the Internal Committee, in the manner as may be prescribed. Both limbs sit in the same clause. Failure to comply with the provisions of the Act attracts a fine which may extend to fifty thousand rupees under Section 26(1), and Section 25 empowers the appropriate Government to call for information and inspect records.
The Act says "at regular intervals" for employee workshops and awareness programmes, and does not fix a number. In practice the interval an employer chooses has to be defensible against its own facts — attrition, headcount growth, shift patterns and how many sites it runs. An organisation that hires continuously and trains once a year has a large untrained population at any given moment. Most employers we advise settle on an annual all-staff cycle with induction coverage for new joiners and a separate refresher for managers, which is what makes the "regular intervals" claim evidenced rather than asserted.
They have different audiences and different content, and Section 19(c) treats them separately. Employee workshops sensitise the workforce to what the Act prohibits and how to complain. Committee orientation equips the people who will actually run an inquiry — the ninety-day limit in Section 11(4), the ten-day report in Section 13(1), the sixty-day employer action in Section 13(4), the rule in Section 10 that conciliation happens only at the aggrieved woman’s request and never on a monetary settlement as its basis, and the caution in Section 14 that a mere inability to substantiate a complaint is not by itself a basis for action against the complainant. A committee that has only sat through the staff deck is not oriented.
The Act does not license trainers, so the question is really what the session has to withstand. Where training is delivered by advocates who also take external member seats and advise on inquiries, the content is anchored to the provisions and to how findings are actually tested afterwards, rather than to generic workplace-conduct material. Our sessions are delivered by advocates from the firm’s partner-led team, and the same team can be retained for the Internal Committee orientation limb.
Yes, and for distributed teams it is often the only way to reach everyone within a cycle. The Act does not prescribe a delivery medium. What matters is that attendance is recorded, that the content covers the Act rather than a generic module, and that the Internal Committee orientation is run as its own session rather than folded into the all-staff broadcast. We deliver on site across Delhi NCR and virtually for teams in other States.
At minimum: the definition of sexual harassment in Section 2(n), which includes physical contact and advances, a demand or request for sexual favours, sexually coloured remarks, showing pornography, and any other unwelcome physical, verbal or non-verbal conduct of a sexual nature; the five circumstances in Section 3(2) that may amount to sexual harassment, including implied or explicit promises of preferential treatment and the creation of an intimidating, offensive or hostile work environment; who counts as an employee under Section 2(f) and what counts as a workplace under Section 2(o); the complaint route and the three-month limit in Section 9(1); and confidentiality under Section 16.
Yes, and this is one of the points training most often gets wrong. Section 2(f) defines an employee as a person employed at a workplace for any work on regular, temporary, ad hoc or daily wage basis, either directly or through an agent including a contractor, with or without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, and expressly includes a co-worker, contract worker, probationer, trainee and apprentice. The working population of a site — facilities, security, transport, agency staff, interns — is almost always larger than its payroll, and training scoped to payroll leaves the gap uncovered.
Section 16 opens with the words "Notwithstanding anything contained in the Right to Information Act, 2005", and then prohibits publication or communication of the contents of the complaint, the identity and addresses of the aggrieved woman, the respondent and witnesses, any information relating to conciliation and inquiry proceedings, the Committee’s recommendations, and the action taken. Section 17 provides the penalty where a person entrusted with handling the matter contravenes Section 16. This is a point worth covering in Committee orientation, because it governs how minutes are written, circulated and stored.
Enough to evidence the Section 19(c) duty if it is questioned. That normally means dated attendance records for each session, the material used, separate evidence of the Internal Committee orientation as distinct from staff workshops, and a record of induction coverage for joiners. The same file supports the Section 19(b) display obligation and the annual reporting under Sections 21 and 22, and it is the file that answers a Section 25 call for information or inspection of records.
Senior Partner, LLM, MBA (XLRI Jamshedpur). Reviewed with the advocates and associates of Unified Chambers and Associates, a partner-led practice at the Delhi High Court Complex.
Last reviewed: 26 August 2026
Provisions on this page are cited to the enacted text, not to a secondary summary.
Tell us your headcount, how many sites you run and whether your Internal Committee has ever been oriented, and we will come back with a cycle that discharges both limbs of Section 19(c) and leaves a file behind.
This page is general legal information about the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the services the firm provides. It is not legal advice, and no advocate–client relationship arises from reading it. Advice on any particular workplace depends on its own facts.