You’ve ticked every POSH box. So why might your IC still fail?
✔ You have a duly constituted IC as statutorily mandated
✔ Your IC has been trained to conduct inquiries
✔ It receives regular legal updates
✔ Members were selected without bias, on seniority and functionality
✔ They’re approachable
Then where lies the gap?
In assuming that a committee once set up stays in working order.
An IC that was valid in January may not be valid in October. Members leave. They change roles. They go on long leave. Their tenure ends.
Every change calls for:
🔹 A fresh written order
🔹 Updated records and workplace notices
🔹 Updated details on the SHe-Box portal
That last one isn’t just paperwork. If a member who has left is still listed, a complaint can reach that person instead of the current committee. That’s a confidentiality breach, and the complaint is delayed before the inquiry has even begun.
Where organisations commonly slip:
- Not reconstituting the IC after someone leaves or is absent on account of maternity leave.
- No proof that employees were ever informed about who sits on the IC panel.
- No IC at all at branches with 10 or more employees.
- An IC where no external NGO member was appointed.
- Inquiry files kept incompletely or retained inconsistently by the IC.
- Complaints settled informally outside the IC, which bypasses the Act altogether.
When did your organisation last review its IC?