ICSI Policy on Prevention, Prohibition and Redressal of Sexual Harassment at Workplace (2025): A Comprehensive Overview
The Institute of Company Secretaries of India (ICSI) has rolled out a revised and comprehensive Policy on Prevention, Prohibition and Redressal of Sexual Harassment at Workplace, which came into force on 19 August 2025. This policy supersedes all earlier policies and communications on the subject issued by ICSI. Rooted in the framework of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (PoSH Act) and the rules made thereunder, the new policy goes a step further by adopting a gender-neutral approach — extending protection to all employees regardless of their gender identity.
This article presents a structured walkthrough of the policy's key provisions, scope, redressal mechanisms, committee compositions, and compliance obligations.
Policy Statement and Foundational Commitment
ICSI's policy is anchored in the principle that every individual working within or interacting with the Institute deserves a safe, respectful, and non-hostile environment. The policy recognises the dignity of each person as non-negotiable and commits to addressing any form of sexually oriented misconduct with full seriousness and confidentiality.
Key Commitment: ICSI operates with a zero-tolerance stance toward any form of sexual harassment occurring at or in connection with its workplace, whether during or outside regular working hours.
All reported complaints will be treated with gravity, impartiality, and strict confidentiality throughout the redressal process.
Scope of the Policy
Statutory Basis vs. Extended Coverage
The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 is, by statutory design, applicable only to women employees. However, ICSI's policy consciously broadens this scope to encompass individuals of all genders, enabling any employee — regardless of gender — to file a complaint under this framework within the workplace context.
Important Note: In any situation where there is a conflict between the terms of this Policy and the provisions of the PoSH Act, the PoSH Act shall prevail. Similarly, local laws of any other geography shall take precedence over this Policy, where applicable.
Applicability: Who Is Covered?
The policy applies to a wide range of individuals connected with ICSI's functioning:
Covered Persons include:
- Full-time, part-time, temporary, ad-hoc, or daily wage employees, whether engaged directly or through an intermediary or agent
- Contractual personnel, probationers, trainees, apprentices, and interns
- Customers, vendors and their staff, consultants, and any other persons conducting business at ICSI premises
- Students, members, guests, visitors, and any others present at the ICSI Workplace
Excluded from Coverage:
- Personal interactions or engagements between individuals, even if such interactions originated in a workplace setting
- Complaints that do not fall within the defined scope of sexual harassment under this policy
Key Definitions
Aggrieved Person
An individual — whether or not employed — who alleges that they have been subjected to an act of sexual harassment by the Respondent.
Complainant
Either the Aggrieved Person themselves or a duly authorised representative raising the complaint on their behalf.
Employee
Any person employed at the workplace for any form of work — regular, temporary, ad-hoc, or daily wage — directly or through an agent or contractor, with or without the principal employer's knowledge, whether remunerated or not, including co-workers, contract workers, probationers, trainees, and apprentices.
Employer
The person responsible for the management, supervision, and control of the Workplace.
Respondent
The individual against whom the complaint of sexual harassment has been filed.
Definition of Sexual Harassment
Sexual harassment under this policy is understood broadly. It encompasses not only situations where sexual behaviour is used to control, influence, or affect an individual's career, salary, or job, but also misconduct between colleagues or between an employee and any third party encountered in the course of work.