The annual PoSH training session is simultaneously the most visible compliance activity an employer undertakes and the one most frequently done wrong. A one-hour slide deck, a generic video module, or an unsigned attendance sheet — these are not compliance. They are the appearance of compliance, and that distinction matters enormously when a district officer requests documentation.

"The training record is the first document a district officer asks for. Most companies can't produce one."

Here is what the Act and Ministry guidelines actually require — and where most organisations fall short.

Mandatory Module 1: Definition of Sexual Harassment

Module 01
The five forms of sexual harassment under Section 2(n)
Employees must understand all five forms explicitly listed in the Act: (1) physical contact and advances; (2) a demand or request for sexual favours; (3) making sexually coloured remarks; (4) showing pornography; (5) any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature. Many training programmes cover only physical harassment. The Act's definition is substantially broader, and employees must know this.

The training must also cover what constitutes "unwelcome" conduct — a concept that is subjective and context-dependent. The definition of harassment is not limited to explicit or severe acts; repeated subtle conduct that creates a hostile work environment falls within Section 2(n)(v). This nuance is missing from most generic training materials.

Mandatory Module 2: IC Composition and Role

Module 02
Who sits on your IC and what they do
Every employee must know who the IC members are by name, their contact details, and what the committee's function is. This is not optional — Section 19(b) requires the employer to display this information. Training should include a review of the current IC composition, the role of the External Member, and why the committee is independent of management.

Mandatory Module 3: The Complaint Process

Module 03
How to file a complaint: timeline, format, and confidentiality
Employees must understand how to file a complaint in writing, the 3-month deadline from the date of the last incident (extendable for good reason), what information is needed, and the confidentiality obligations that protect all parties. Training that covers definitions but skips the complaint process leaves employees unable to use the protection the Act was designed to provide.

Mandatory Module 4: Consequences of Proven Harassment

Module 04
What happens to a respondent found guilty
Section 13 gives the IC authority to recommend action against the respondent: written apology, warning, reprimand, withholding of promotion or increment, termination of service, or other remedies as appropriate. Training should be explicit about this — deterrence requires awareness of consequences, not just awareness that harassment is wrong.

Mandatory Module 5: Consequences for False Complaints

Module 05
Section 14 — action for malicious complaints
Section 14 of the Act provides for action against a complainant who is found to have made a false or malicious complaint, or to have produced false evidence. This protects the integrity of the process and reassures respondents and employers. Training should cover this without using it as a way to discourage legitimate complaints — a misapplication that can create a chilling effect.

The Common Gaps: What Most Training Gets Wrong

Covering definitions but not the complaint process An employee who knows what harassment is but doesn't know how to report it has gained nothing practically actionable from the training.
No attendance record A training session without a signed attendance register — or a timestamped digital completion record for online training — is legally the same as no training. The record is the evidence.
Not including contract workers and interns Section 2(n) and the Act's definition of "employee" under Section 2(e) is broad. Interns, contract staff, temporary workers, and apprentices are all covered. Training that excludes them creates a gap precisely in the workforce population that is often most vulnerable.
Online-only training with no live interaction There is no legal bar on online training, but a module with no Q&A and no facilitator creates an artificially clean record without genuine awareness. Questions reveal gaps; if no one asks questions, that is either because the training was exceptionally clear or because no one engaged at all. District officers are increasingly sceptical of completion certificates from zero-interaction online modules.
No separate IC member training Rule 13 of the PoSH Rules, 2013 requires that IC members receive separate sensitisation training. Employee training and IC member training are not the same thing and cannot be conflated.
What This Means for You

Review your last training session against this checklist. If you cannot produce: (a) an agenda covering all five modules, (b) a signed attendance register including contractors and interns, and (c) separate documentation for IC member training — you have a gap. POSH360's annual training programme covers all mandatory modules, produces legally sound documentation, and includes a live Q&A component that meets the standard a district officer expects to see.