11 years have passed since the Prevention of Sexual Harassment (POSH) Act was implemented. However, its workplace adoption in India remains largely compliance-driven, with a culture of inclusivity and safety still a distant goal. The POSH Act, introduced in 2013, mandates organisations to prevent, prohibit, and redress cases of sexual harassment at work.
In a candid conversation with ALL THINGS TALENT, Pallavi Jha Chairperson & Managing Director, Dale Carnegie India & Walchand PeopleFirst, sheds light on the challenges organisations face in making the Act more than just a checkbox exercise. From the lack of awareness among HR professionals to the reluctance of senior leadership to fully embrace its principles, the gaps in implementation are stark. She emphasises that the roadblocks aren’t limited to policies and processes but extend to deeper cultural shifts—creating psychological safety, normalizing diverse workplace behaviours, and addressing generational biases.
Reflecting on the 11 years since the POSH Act was introduced, what changes have you observed in its implementation within organisations? Is it still seen as a mandatory requirement, or has it evolved into something more than just compliance?
Unfortunately, I don't think it has gone beyond compliance yet. It's been 11 years, but even as recently as late 2023, we conducted a study through Walchand Plus on the state of POSH implementation in the Indian corporate sector, and the results were telling. Large, listed, and reputed companies are generally following the POSH Act and taking action, but even these companies often don't have fully constituted Internal Complaints Committees (ICCs) in place within their subsidiaries.
As for small and medium enterprises, there's minimal adoption of POSH. Very few have implemented it at all. Since the Indian corporate landscape is dominated by small and medium businesses, there's still a long way to go before POSH becomes ingrained as a corporate culture. We are still seeing a very low level of adoption, which shows that while it might be viewed as a mandatory requirement, it hasn't yet evolved into something more holistic or ingrained in the way organisations function.
The increase in complaints, however, certainly indicates that reporting is improving, which is a positive sign. While it's encouraging that more employees are coming forward, we can't yet say that the system is fully effective or that we have reached a point where we can be truly proud of the progress. There's a lot of work to be done to foster genuine change.
What do you think is still lacking in workplace culture that prevents significant improvement in areas like employee safety, inclusion, or empowerment? What key elements or practices need to be integrated to drive meaningful and lasting change?
Let’s start with POSH adoption, as it’s a crucial part of this discussion. Even today, POSH is largely treated as a compliance checkbox—something organisations do to remain on the right side of the law and include in their annual reports. However, our research found that more than half of the HR managers interviewed were not fully informed about POSH guidelines. If HR managers themselves lack clarity, it reflects how incomplete and superficial the adoption is.
One major challenge is the lack of senior leadership support. Without leadership walking the talk, it’s impossible to create meaningful cultural change. Many organisations, especially outside of large multinational companies, do not have properly constituted Internal Complaints Committees (ICCs). There's little to no awareness or training, and audits to assess the effectiveness of these measures are practically non-existent.
The situation is even more challenging for employees. Many victims of harassment face barriers like shame, fear of retaliation, and uncertainty about how to report incidents. Even when mechanisms exist, they are often opaque, which discourages employees from coming forward. Moreover, many individuals—including the accused—are not adequately educated about what constitutes harassment. Behaviours like invading someone’s personal space or making inappropriate comments are not always recognised for what they are, due to deeply ingrained attitudes and biases.
To foster a truly inclusive and empowering workplace culture, organisations need to focus on three critical areas:
- Education and Training: Comprehensive education on harassment, inclusion, and unconscious biases is essential. Both employees and leaders must understand not just the rules but also the underlying values of respect and dignity. Changing attitudes and biases is a slow process, but it begins with awareness and consistent reinforcement.
- Leadership Commitment: Senior leadership must actively champion employee safety and inclusion. Without visible, consistent support from decision-makers, policies remain mere words on paper. Leaders need to set an example by creating a culture where reporting harassment feels safe and non-punitive.
- Psychological and Physical Safety: While POSH focuses on physical safety, creating psychological safety is equally important. Employees must feel secure in voicing concerns without fear of retaliation. This includes ensuring swift and transparent redressal processes, simplifying reporting mechanisms, and protecting employees from potential backlash.
When organisations prioritise these elements, the business benefits become apparent—diverse teams bring innovative ideas, collaboration improves, and productivity rises. However, the change requires persistence and commitment. Sharing successful case studies and best practices can inspire others, but even large organisations that are seen as leaders in diversity and inclusion have much room for improvement.
How can organisations address generational differences in perceptions of harassment and create a universally respectful and inclusive work environment?
We’re living in an era where even our understanding of gender is evolving. While some may identify as male, female, or non-binary, others—particularly from older generations—struggle to grasp this shift. For them, terms like "they" as a pronoun or understanding non-binary identities can be confusing. This generational gap creates challenges in defining what harassment is and how to build inclusion. However, the core values of dignity and respect remain universal. The key lies in establishing a common value system. While we may differ in how we express ourselves, we all agree that dignity and respect are fundamental. The challenge is how we ensure these values are upheld, regardless of generational differences. One approach could be to use context-appropriate examples—movies, storytelling, or real-life experiences—that resonate with different generations.
For instance, I recently attended the International Convention of Dale Carnegie, where they republished How to Stop Worrying and Start Living. The book had to be rewritten for modern language, including gender-neutral terms. There was even debate over whether to use the term “Negro,” as it’s no longer acceptable. Such discussions highlight the generational gap in language and understanding.
How can leaders move beyond gestures to build a culture of accountability and fairness, streamline complaint systems, ensure transparency, and promote inclusivity?
Leaders must prioritise inclusivity at every level and lead by example. A diverse leadership team, where women have equal respect and a voice at the table, demonstrates authenticity and commitment to fairness. Creating a 'speak-up culture' is crucial. Employees need to feel safe to report issues without fear of retaliation, especially in cases involving those in positions of authority. Leaders must foster an environment that empowers individuals to voice concerns confidently. To achieve this, leaders should engage in open conversations and debates across all levels of the organisation, ensuring transparency and accessibility. This not only builds trust but also sets the tone for a culture of accountability and fairness.
Do compliance-only approaches impact talent retention and attraction?
Today, we live in a world of glass-door reviews. Many employees may not openly share their thoughts when leaving an organisation, not even during exit interviews. However, their experiences often surface later through online company reviews. This reality underscores the importance of leaders being extremely mindful and inclusive while fostering a culture of trust and respect.
The reputational risks of not doing so are significant. Leaders often worry about these risks, but the cost of neglecting diversity and inclusion is far greater. When you have a diverse and inclusive team where people feel respected, valued, and empowered to speak up, it fosters collaboration, sparks creativity, and accelerates innovation. This, in turn, boosts productivity. By cultivating a culture of success, you engage your workforce—employees feel valued, heard, and appreciated, which leads to greater job satisfaction, higher performance, and a sense of belonging.
On the flip side, if employees feel ignored, harassed, or too afraid to speak up, they will disengage. Eventually, they will leave, and many will share their negative experiences with others—possibly reaching millions online. This damages your organisation's reputation, making it harder to attract and retain top talent. It’s often said that while raising money might be easy, building and sustaining a strong, motivated team is the real challenge.
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What advice would you give employees facing microaggressions or serious violations at work on reporting them to managers or committees?
Employees facing microaggressions or severe violations must approach their complaints with integrity and clarity. Establishing trust and credibility in your complaint is key. Avoid framing the issue as purely emotional; instead, focus on presenting facts.
It’s also important to understand that not every misconduct has a single resolution. Misdemeanours vary in severity, and committees—ideally diverse and fair—evaluate them accordingly. A minor offence might warrant a warning or education, while a severe one could lead to termination. Expecting termination as the default outcome for all complaints can lead to dissatisfaction and unrealistic expectations.
Organisations must create clear, inclusive policies that define acceptable behaviour and outline the reporting process in simple, accessible terms. A ‘speak-up culture’ is essential, where employees feel safe to voice concerns. However, this culture needs reinforcement through continuous education, clear communication, and rewarding positive behaviour.
Training plays a critical role in addressing microaggressions, fostering awareness, and ensuring alignment on expected behaviours. Over time, this builds a respectful and dignified workplace where concerns are acknowledged and addressed appropriately.
Should education and awareness programmes be integrated into onboarding to establish clear organizational values and appropriate behaviour from the start?
I think so, and we have recently started integrating education and awareness programmes into our onboarding process. While we are a female-centric organisation where speaking up internally comes more naturally, all organisations need to set the right tone from the beginning.
Starting with an online learning experience during onboarding is a good way to establish foundational values, but it shouldn’t stop there. It's important to recognise that we are working with a multigenerational workforce, and people consume knowledge differently. Some prefer quick, on-the-go learning modules, while others, especially older employees, may benefit from in-person programmes.
This education must also extend beyond employees. ICC (Internal Complaints Committee) members need to be thoroughly trained in the law, managers must understand how to handle complaints effectively even if they aren't part of the ICC, and all individuals should be made aware of what constitutes appropriate behaviour. Women, in particular, should be guided on how to file complaints and what steps to take if things don't go as expected.
Ultimately, this isn’t a one-time initiative—it requires continuous reinforcement throughout the year. It also demands strong leadership to drive these efforts and ensure accountability at every level.
Mamta Sharma is a freelance journalist committed to sharing stories on talent management, DEIB, workplace culture alongside narratives on leadership, entrepreneurship, tech innovation and employee wellbeing.
