ICSI Gender-Neutral Policy on Workplace Sexual Harassment 2025: Coverage, Committees and Timelines
Introduction
The Institute of Company Secretaries of India (ICSI) has issued a Policy on Prevention, Prohibition and Redressal of Sexual Harassment at Workplace, in force from 19 August 2025. It replaces all earlier policies and communications on the topic. The Policy is built around the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (the "PoSH Act") and the rules framed under it, but it is broader in reach.
Policy Commitment
The Institute states that it is committed to a safe, non-discriminatory and non-hostile working environment free from sexually natured intimidation or harassment, where every employee is treated as an equal and their dignity is protected. It follows a zero-tolerance approach to sexual harassment, and every complaint is to be taken seriously and handled respectfully and in confidence.
Scope and Gender-Neutral Character
The Policy deals with the process of investigating and redressing sexual harassment complaints at the workplace. The PoSH Act protects women employees only, but the ICSI Policy extends its benefits to all employees irrespective of gender, so any employee may lodge a complaint under it.
Two precedence rules apply:
- If the Policy and the PoSH Act conflict, the PoSH Act prevails.
- In other geographies, local laws take precedence over the Policy.
Who is covered
- Employees, whether full-time, part-time, temporary, ad-hoc or daily wage, engaged directly or through an agent, including contractual personnel, probationers, trainees, apprentices and interns.
- Customers, vendors and their employees, consultants and anyone else doing business at the ICSI Workplace or interacting in connection with work done by or for the organisation.
- Anyone present at the Workplace, such as students, members, visitors and guests.
What is excluded
- Interactions in a personal capacity, even if they began at the Workplace.
- Complaints that do not fall within the definition of sexual harassment.
Key Definitions
- Aggrieved Person: anyone, employed or not, who alleges being subjected to sexual harassment by the Respondent.
- Complainant: the Aggrieved Person or someone authorised by that person to raise the complaint.
- Respondent: the person against whom the complaint is made.
- Employer: the person responsible for management, supervision and control of the Workplace.
- Employee: a person employed at the workplace on a regular, temporary, ad-hoc or daily wage basis, directly or through an agent (including a contractor), with or without the principal employer's knowledge, paid or voluntary, and including co-workers, contract workers, probationers, trainees and apprentices.