POSH Policy Drafting & Documentation

A POSH policy copy-pasted from a template site, with the company name swapped in, is one of the most common — and most quietly risky — shortcuts we see. It technically exists, which satisfies a surface-level audit question, but it rarely reflects your actual workforce structure: whether you use contract staff, operate across multiple states, run a hybrid model, or engage vendors and clients on-site. When a real complaint arrives, gaps in a generic template become obvious fast, and not in a good way.

Documentation built around how your organisation actually operates

Every document produced through this practice is drafted specifically for your organisational structure, not adapted from a generic starting point:

• POSH policy drafting and review — a policy that explicitly addresses your actual scope: office premises, client sites and business travel, remote work, and any contract, gig, or intern workforce you engage. If your current policy only addresses "in-office" conduct, it's already out of step with how courts have interpreted the Act's definition of workplace — see our post on POSH applicability to work trips, client sites, and off-site events.
• ICC constitution orders and nomination letters — formally documenting Presiding Officer appointment, employee members, and external member credentials, so composition can withstand scrutiny if ever challenged. Our post on Internal Committee composition covers exactly what this documentation needs to demonstrate.
• Annual report preparation — compiling and formatting the statutory report to the District Officer under Section 21, built from a running log rather than reconstructed under deadline pressure. See our detailed guide to this filing.
• Board Report and disclosure support — for companies that need POSH figures reflected in company-law filings and, where applicable, listing or BRSR disclosures, reconciled against the same underlying data used for the District Officer report. Covered in depth in our post on POSH disclosure in board reports and annual returns.
• Workplace compliance posters and notices — the mandatory Section 19 display materials, drafted to be genuinely legible and useful, not a wall-filler nobody reads.

Why generic templates fail in practice

The gaps we most often find when reviewing an existing template-based policy: no reference to remote or hybrid work, no provision addressing contract or gig workers, vague or outdated committee composition language, and no clear escalation path for complaints involving a founder or senior leader — a scenario with its own distinct legal routing, which we cover in our post on founders and promoters under POSH. Each of these gaps is invisible until it matters, and by then it's the worst possible time to discover it.

A documentation set that actually holds together

Policy, ICC orders, and annual reports aren't treated as separate, disconnected deliverables — they're built to be internally consistent, so the committee composition your policy describes matches your actual nomination orders, and the figures in your annual report reconcile cleanly with any board-level disclosure. This consistency is exactly what compliance audits, investor due diligence, and (in the worst case) a legal challenge will actually test.

Ongoing maintenance, not a one-time document

POSH documentation isn't a set-and-forget deliverable — IC member terms expire, headcount crosses thresholds, and annual filings recur every year. Engagements can be structured as a one-time drafting project or an ongoing annual retainer that keeps your documentation current without you having to track every renewal date yourself.

Getting started

Share your current policy (if one exists), headcount, locations, and workforce mix — including any contract, intern, or gig workers — and we'll assess what's missing and what needs updating, rather than starting from a blank template regardless of what you already have.