Let me take you back a little—back to the days when television was simpler, and Yes Minister ruled our screens. A brilliant show, capturing the art of bureaucracy with its dry wit and sharp insight. If you’ve watched it, you’ll recall how ministers often appeared in charge, but the real puppeteers were hidden behind walls, pulling invisible strings.
Role of the External Member
Now why do I bring up Yes Minister while talking about POSH Compliance and POSH Training? Because, believe me, there was a time (and sometimes still is) when an External Member (EM) was seen exactly like that—just a rubber stamp. A formality. Someone expected to sit in meetings, nod dutifully, and sign where needed.
But let me rewind a little more—before the satire, before the challenges.
The POSH Act, 2013 in India is a beautifully drafted law, not just for compliance purposes but for real cultural change. It mandates the constitution of an Internal Committee (IC) to investigate workplace sexual harassment complaints, and importantly, requires the inclusion of an External Member.
This External Member should ideally be a subject matter expert from a legal background, social sector, or with a minimum of five years of deep experience with POSH cases. The role demands neutrality, sensitivity, and capability — all values we focus on during POSH Certification programs at NoMeansNo.
From Proxy to Protector: POSH Certification Lessons in Action
When I began my journey as an External Member over a decade ago, I realized how often organizations misunderstood the role.
At times, External Members were expected to act as proxies—there to validate decisions already made by management.
In those early days, as a younger EM, I sometimes felt overwhelmed. Today, having served as an External Member across 100+ organizations in India and supported overseas operations, I understand my real duty.
Now, I choose the organizations I work with, just as carefully as they choose me.
Because a true External Member does not serve management — we serve the spirit of the POSH Act.
Our POSH Training for Leaders emphasizes exactly this—ensuring that leadership understands an EM’s role is that of a guide, not a subordinate.
In many ways, I see the External Member as Krishna and the Internal Committee (IC) as Arjun.
We guide, offer wisdom, highlight dharma (the right path)—but we do not fight the battle or decide the outcome.
Weapons for the Modern Mahabharat: POSH Training Insights
The capacity building training for ICC members we conduct often focuses on practical tools for inquiries:
- Collecting Evidence smartly
- Documenting Witness Statements properly
- Conducting effective Cross-Examinations
- Applying the Prudent Person Test
- Understanding Preponderance of Probability to reach fair conclusions
These elements are the “weapons” every IC must master during our POSH Certification programs.
Our goal during POSH Training is simple: not just to create compliance experts, but to build warriors of fairness who can protect the organization’s values.
Pressure Points and Principles: POSH Compliance Is Non-Negotiable
Let me share a real example.
Recently, while handling a case for a reputed company, the inquiry clearly established misconduct by a senior leader. Soon after filing the report, I received a phone call:
“Vishal sir, can we tone down the report? Just for internal optics?”
I listened respectfully but responded firmly:
“My duty is to the process and the law, not to internal politics. The facts must be reported as they are.”
This is where POSH Compliance is truly tested — not when it’s easy, but when it’s uncomfortable.
Our POSH Training for Leaders and Capacity Building for ICC Members often revolves around these real-life scenarios—teaching them how to handle subtle pressures while upholding the law.
Upholding Dharma in POSH Certification and Compliance
A true POSH Certification process must instill these values:
- Regular IC meetings to stay connected to real-time issues
- Periodic reviews and reflections on workplace culture
- Capacity building and refresher trainings
- Mock audits and POSH awareness campaigns
- Visibility and accessibility of the IC
- Strict adherence to timelines and principles of natural justice
Through NoMeansNo’s POSH Training modules, I see IC members becoming not just compliant, but conscious custodians of fairness.
Every inquiry I guide is a step closer to a culture where dignity, respect, and safety are non-negotiable.
Kindly be informed that although the term ‘ICC’ is still in common use, it has been officially changed to ‘IC’ (Internal Committee) as per the stipulations of The Repealing and Amending Act, 2016. The official document can be accessed for further reference. here
A Reset for the Future
I believe that every External Member must ask themselves— "Am I here to serve management, or to serve the truth?"
At NoMeansNo, our answer has always been clear. We stand by the spirit of the Act, not by convenience.
In this modern Kurukshetra, POSH Compliance is our battlefield, and integrity is our dharma. And as long as I’m here, I’ll continue being Krishna to every Arjun that steps into this journey with courage, vulnerability, and hope.
