Compliance Checkbox: Why POSH fails in large, complex organizations

POSH) legislation was enacted in 2013, organizations have implemented elaborate compliance systems. They drafted policies and procedures, established internal complaints committees, and delivered training sessions on laws and procedures to prevent sexual harassment. They also designed reporting dashboards, among other activities, to implement and sustain this legislation. Yet there are incidents of failure we hear every now and then that tell a different story.

In diverse, multilocational and multicultural organizations, compliance with POSH often starts with good intent but can quietly lose effectiveness over time. The breakdown isn’t easily visible, as it tends to remain under the surface, becoming apparent only when it has already begun to affect both organizational resources and reputation.

On the ground, a formal system, clearly documented policies, and visible communication via posters and banners may be in place. Yet, despite this apparent structure, the system may fail to deliver the protection it is supposed to provide. What emerges is a gap between intent and real-time execution. Therefore, in people’s eyes, compliance exists as a framework rather than a concrete reality.

In what follows, I will outline some of the underlying reasons for this disconnect, along with the areas that organizational leaders—and particularly HR—need to pay closer attention to close this gap.

A Peek into the Core Issues

Often, at the core of this failure lies possible cultural fragmentation. In large organizations, there are often many subcultures. The corporate office may operate with deeply ingrained progressive values. Meanwhile, remote locations, acquired or merged entities, and geographically dispersed units may still function with deeply entrenched hierarchies and informal structures.

Interestingly, POSH policies and procedures exist as documents and files, but the actual culture shows up as highly localized behavioural adaptations. So, if the organization relies solely on documented mandates and procedures to be consistent with its corporate philosophy, grassroots ownership may be weak.

Closely tied to cultural fragmentation is what I call as the policy-power gap. Senior leaders, such as operations, functional, and regional heads, don’t always comply with the corporation’s ethical expectations. When a successful employee who drives significant revenue or holds key decision-making authority is accused, cracks begin to surface. Investigations get delayed, reworking narratives happens, and neutral judgment gets compromised.

Even if the system bends just a little, employees can lose faith. Things simmer under the burner, waiting for someone bold to raise the issues that those responsible for swept under the carpet. Over time, fuzzy decision-making and closures become an undocumented norm that shields influence from accountability, and the organization’s tolerance for such compromises slowly magnifies.

Another problem is the illusion of awareness. Organizations often view completing a training programme as evidence of culture change. Online learning modules are rolled out, attendance is tracked, and certifications are issued. But awareness without internalization is just skin-deep. Employees may be aware of what constitutes harassment, but the important question is whether they feel psychologically safe raising the issue when faced with such situations.

Managers may understand the rules but lack the resolve to face uncomfortable situations. POSH and its pursuit for the good of the company becomes a language people can speak—but not a principle they live by. So, we find that organizations live with the proverbial knowing-doing gap.

Then comes the issue of watered-down committee effectiveness. Internal Committees are analogous to the spine of the POSH framework. Sometimes they are structurally compliant but functionally weak. Members may not have enough training to tackle sensitive cases. They may not have the freedom to remain unbiased or be given sufficient time to conduct thorough inquiries.

In multi-locational organizations, committees often struggle with basic enablers, such as easy access to people, consistent backing from the corporate office, and confidentiality during sensitive investigations. Over time, these gaps start to show. Employees begin to lose trust in the system, and what should be a safeguard gradually feels like just another process to follow.

A more subtle but powerful factor for the failure of POSH is the fear of consequences. In large organizations, careers are spread over long periods, and people’s networks are tightly coupled and influential. Victims would fear that speaking up can harm their growth, lead to social isolation, and be branded as difficult people to work with. Even when policies promise protection against retaliation, the informal system usually tells a different story. When employees perceive that the cost of speaking up outweighs the benefit, conscious silence becomes rational and the preferred choice.

There is also the problem of data without insight, especially in large organizations, which are good at monitoring anti-sexual harassment and prevention metrics—such as the number of cases, closure timelines, training coverage, and so on. But these metrics sometimes create a false sense of control.

A low number of complaints may be celebrated as a sign of a healthy culture, when in reality it could indicate suppression or fear. Without qualitative listening via employee pulse checks, anonymous narratives, and exit interview insights, the organization risks mistaking the absence of noise for the absence of problems.

Further organizations should have mechanisms to address resistance or fear of raising grievances within their systems or portals. Organizations should ensure a robust listening mechanism that allows leaders responsible for employees’ safety and wellbeing to take forward such issues for review when approached by any affected employee.

Perhaps the most overlooked reason is leadership intent signalling. We know from psychology that employees don’t just listen to their leaders; they also model them. They tend to watch leaders’ actions far more than they read policies.

A single instance in which a senior leader trivializes a complaint, makes an inappropriate remark, or shields a high performer can undo years of communicating the policy’s essence. Conversely, visible, consistent, and courageous leadership can transform the system overnight. In large organizations, where there are many leaders and messages diffuse, inconsistency becomes the easily visible norm, making trust fragile.

Moving from Compliance to Conviction

How do we shift POSH’s focus from compliance to conviction? It begins with local ownership of an organization’s global standard—making sure that every business unit or department, regardless of size or location, internalizes the policy’s spirit. It requires strictly decoupling ethics from performance, so that no individual is “too valuable” to be held accountable. This is one of the most critical show stoppers if not tackled from the early days of pursuing strategies to prevent sexual harassment.

Further, organizations should focus on deep capability development for Internal Committees. Apart from legal aspects and processes, focus should also be on empathy, inquiry, and judgment. It calls for psychological safety as a measurable leadership outcome.

Organizations should focus on making POSH conversations continuous rather than reactive, and only when things go wrong. When awareness is reduced only to annual training modules, it signals obligation. For it to move beyond that, it should become part of everyday dialogue—in team meetings, employee town hall communications, and onboarding sessions. Culture is not built in workshops, but in what is repeatedly spoken about and acted upon. It has to breathe within the organization’s structural matrix.

Equally, organizations must institutionalize transparency without damaging confidentiality. Sharing anonymized case trends, resolutions, and learnings creates credibility in the system. When employees see that action is real and consistent, trust replaces scepticism, and reporting becomes an act of faith rather than fear.

There is also a need to integrate POSH metrics into leadership scorecards. What leaders tolerate, they ultimately endorse and symbolize as important to the rest of the organization. When indicators such as team climate, responsiveness to grievances, and the spirit of equity are included in performance evaluations, accountability shifts from mere symbolism to a structural one.

Finally, organizations must recognize that prevention is not only about redressal. It is also about design. Someone must review workplace structures, authority relations, reporting hierarchies, and informal networks through a gender-sensitivity lens. A system that unconsciously concentrates power or discourages voice will always struggle to uphold POSH, no matter how strong the policy appears on paper.

Ultimately, POSH becomes real, not when someone enforces it, but when it is embedded—quietly, consistently, and courageously—into the way an organization chooses to function every single day. Therefore, organizations should move from asking, “Are we compliant?” to asking, “Do our people feel protected?”

Because in the end, POSH does not fail for lack of policy. It fails when systems value reputation over reality, process over people, and silence over truth. As long as the aggrieved remain silent, things won’t improve. And within that silence, the very purpose of POSH is lost.

DISCLAIMER: The views expressed are solely of the author and does not necessarily subscribe to it. will not be responsible for any damage caused to any person or organisation directly or indirectly.