How to Form an Internal Complaints Committee (ICC) under POSH

An ICC must have a minimum of four members. The Presiding Officer must be a senior female employee. At least two members must be employees committed to women's causes or with social work experience. One member must be an external expert from an NGO, legal background, or someone familiar with women's issues. The external member must not be from within the organisation.

The Presiding Officer of the ICC must be a woman employed at a senior level at the workplace. She must be from the same workplace if possible. If no senior female employee is available, the Presiding Officer can be nominated from another office or administrative unit of the same organisation.

ICC members serve a term of three years from the date of nomination or appointment. After the term expires, members must be re-nominated or replaced. Organisations should track ICC member tenures to ensure continuity and avoid gaps in the committee.

The POSH Act requires at least one ICC member to be from outside the organisation — specifically from an NGO committed to the cause of women, a legal background, or someone with relevant expertise. The remaining members must be employees of the organisation.

ICC members must be trained on the provisions of the POSH Act, complaint handling procedures, confidentiality requirements, inquiry processes, and trauma-informed approaches. Untrained ICC members conducting inquiries can expose the organisation to legal challenge. POSH training for ICC members should be repeated when new members join.