False Complaint Vs Not Provided Compliant
1. Editor’s Note: A False POSH Complaint Is Not the Same as an Unproved One 2. Legal Lens: What Section 14 Says…
9 min read Read More1. Editorial: Is Your POSH Training Changing Behaviour or Just Recording Attendance?
2. Judgment Lens: What Have the Courts Actually Said About Training
3. Research Lens: Does Sexual-Harassment Training Actually Work?
4. L&D Corner: So What Should Change?
5. IC Corner: IC Training is Skill Training
6. Culture Cue: Build a Better POSH Training Dashboard
Editorial: Is Your POSH Training Changing Behaviour or Just Recording Attendance?
POSH training has become part of the annual compliance routine in most organisations. Employees attend the session, complete the module, answer the assessment and then go back to their normal working lives, often with very little visibly changing afterwards.
After a few years, familiarity itself becomes a challenge. Employees have heard the definitions before. They recognise the obvious examples. They know which answer is likely to pass the assessment. At some point, mandatory harassment training can even become material for workplace jokes, memes, stand-up routines and social-media reels. That does not prove that the training has failed, but it is a useful signal that something meant to provoke reflection can easily become routine enough to be tuned out.
Research gives us a stronger reason to pay attention. A 2022 meta-analysis by Mark Roehling, Dongyuan Wu, Min G. Choi and James Dulebohn, published in Personnel Psychology, examined research on sexual-harassment training. It found that training was very effective at increasing factual knowledge, but the effect became much smaller when researchers looked at attitudes, practical skills and, most importantly, whether people actually carried the learning into their behaviour afterwards.
That gap is what organisations should be interested in.
Knowing the definition of sexual harassment is useful. But can employees recognise behaviour when it is subtle? Can a manager respond properly when someone says, “Something happened, but I am not sure whether I want to complain”? Can an employee recognise the effect of power dynamics, persistent messaging or digital boundaries? Can a colleague intervene safely when something feels wrong?
Perhaps the question after this year’s training should therefore not only be, “What percentage of employees completed it?”
It should also be, “What can they do differently because they completed it?”
POSH training fatigue is not an argument for less training. It is an argument for training that evolves.
Judgment Lens: What Have the Courts Actually Said About Training
Aureliano Fernandes v. State of Goa, Supreme Court, 2023
The Court required employers and authorities to take “immediate and effective steps” to familiarise IC members with their duties and with how an inquiry should be conducted from the receipt of a complaint until submission of the final report.
It separately directed organisations to regularly conduct orientation programmes, workshops, seminars and awareness programmes to upskill committee members and educate employees about the POSH Act and Rules.
There are two useful lessons here.
First, the Court did not describe POSH learning as a one-time activity. It specifically used the word regularly.
Second, it distinguished between employee awareness and committee capability. An employee awareness module and training someone to conduct a legally sound inquiry are not the same learning requirement.
The Supreme Court subsequently continued monitoring implementation of these directions and asked governments and authorities to report whether effective steps had actually been taken to familiarise committee members with inquiry procedure. Training therefore became something whose implementation the Court was examining, not simply a recommendation buried in a judgment.
Initiatives for Inclusion Foundation & Anr. v. Union of India & Ors, Supreme Court, 2023
The Supreme Court went further when looking at the wider POSH implementation machinery.
It said District Officers, Local Committee members and nodal officers must first be sensitised to the nature of sexual harassment and gendered interactions in the workplace, and directed State Governments to organise periodic and regular training sessions for them.
This is important because it moves training beyond knowledge of sections and procedures. The Court is effectively recognising that people responsible for implementing POSH also need to understand the behaviour and workplace dynamics behind the law.
Research Lens: Does Sexual-Harassment Training Actually Work?
Training Improves Knowledge Much More Easily Than Behaviour
The 2022 Personnel Psychology meta-analysis, “The Effects of Sexual Harassment Training on Proximal and Transfer Training Outcomes,” combined findings from previous sexual-harassment training studies.
The result can be explained simply:
In other words, teaching someone the rule is relatively easy.
Getting the rule to influence what they actually do at work is much harder.
That is probably the most important research finding for organisations reviewing annual POSH training.
An Indian Experiment Showed That Training Can Reduce Harassment
Researcher Karmini Sharma, working with J-PAL South Asia and Safecity, conducted a randomized evaluation of sexual-harassment awareness training in Delhi between 2019 and 2022.
The study covered:
- 3 colleges
- 162 classes
- 2,007 women
- 3,398 men
After training, awareness of legal mechanisms increased by around 15 percentage points, while recognition of ambiguous sexual-harassment situations increased by around 4.5 percentage points.
More interestingly, female classmates reported a reduction in harassment from trained men. Extreme forms of harassment fell by approximately 1 percentage point in the short
run. The researchers estimated that this corresponded to roughly 51 fewer women out of 1,200 experiencing extreme harassment during an academic year.
There was another interesting finding. The training did not produce a clear short-term improvement in men’s victim-blaming attitudes. What did change was their perception of whether their peers approved or disapproved of harassment.
That tells us something useful about training design.
Behaviour may change not only because someone personally changes their beliefs, but because training makes the social norm clear: “People around me do not consider this behaviour acceptable.”
The study was conducted among college students, so the findings should not simply be transplanted into corporate workplaces. But the learning-design implication is valuable: scenarios, discussion, peer norms, empathy and
The Problem Is Not Unique to POSH Training
Gallup research on broader ethics and compliance training found that only around 1 in 10 employees strongly agreed that their training had changed how they actually did their work.
It also found a difference in how employees experienced training formats. Only 17% rated fully digital compliance training as excellent, compared with 30% for in-person training and 28% for blended programmes.
This is not POSH-specific research, but it highlights the same challenge faced by most mandatory compliance learning: completion is considerably easier to achieve than behavioural transfer.
L&D Corner: So What Should Change?
A first-time employee may still need the foundation: what sexual harassment means, what the policy covers, who the IC members are and how complaints can be raised.
Someone completing POSH training for the fifth year probably does not need exactly the same experience again.
Refreshers can instead focus on situations requiring judgment: digital communication, power dynamics, repeated personal attention, bystander intervention, inappropriate humour, manager first response and what happens after someone reports.
The audience also matters. Managers need practice responding to disclosures. Senior leaders need to understand power and accountability. IC members need inquiry skills. Employees need recognition and reporting skills. Vendor-facing teams may need third-party scenarios.
One module cannot realistically do all of these jobs equally well.
Reinforcement can also be distributed through the year instead of loading everything into one annual event. A five-minute scenario three months later, a manager discussion prompt, a case-based microlearning or a short digital-boundaries refresher may do more for retention than another twenty slides added to the annual course.
The design question therefore becomes very simple:
What behaviour do we want this audience to perform differently after the training?
Start there. Then design the learning.
IC Corner: IC Training is Skill Training
The distinction becomes even more important for Internal Committee members.
The Supreme Court in Aureliano Fernandes specifically called for IC members to be familiarised with their duties and with the manner in which an inquiry ought to be conducted.
That cannot be achieved through awareness training alone.
IC members need to practise receiving a complaint, framing questions, examining evidence, dealing with inconsistent accounts, managing digital evidence, applying natural justice, maintaining confidentiality and writing reasoned findings.
Mock inquiries can test questioning skills. Case discussions can expose members to ambiguous situations. Evidence exercises can teach them to distinguish an allegation that is unproved from one that is deliberately false. Report-writing exercises can reveal gaps that a presentation on the Act will never expose.
Culture Cue: Build a Better POSH Training Dashboard
Most POSH training dashboards contain one dominant number:
Completion: 98%.
Keep it. It is an important compliance measure.
But add a few more numbers.
30-Day Scenario Score
A month after training, give employees a new workplace scenario they have never seen before. Can they recognise the concern and choose an appropriate response?
Reporting Pathway Recall
Without reopening the module, what percentage of employees can identify where or to whom they should report a POSH concern?
Manager First-Response Score
Give managers a short disclosure scenario. Can they respond without investigating, dismissing, promising secrecy or attempting to resolve the issue themselves?
Reporting Confidence
Ask employees anonymously whether they believe they know how to raise a concern, whether confidentiality will be respected and whether they can report without fear of negative consequences.
IC Capability Check
Instead of asking whether IC members attended training, test them through a mock case. Can they identify procedural steps, apply natural justice and write a defensible finding?
Now the training dashboard starts answering a different question.
Not only: “Did we train everyone?”, but “Did the training leave us more capable than we were before?”
That is a much more useful measure of POSH awareness.