NHRC’s women’s safety advisory: what should HR do next?

Illustrative stock photograph of two people walking outside an office building. Photo by Pavel Danilyuk via Pexels. The people pictured are not connected with the scenarios discussed, Ungender or the NHRC advisory.

Imagine this: a woman finishes a late shift, but her cab has not arrived. The transport contact is unavailable. She calls HR because she does not know who else can help. In another team, an employee wants to raise a sexual-harassment concern but cannot find the Internal Committee’s contact details.

These are illustrative situations, not client accounts. They are also useful starting points for reading the National Human Rights Commission’s women’s safety advisory. Both ask something practical of an employer: can a person get help when she needs it?

Dated 23 October 2026 and announced on 27 October, the advisory brings workplace safety into the same conversation as transport, public spaces, survivor support and online abuse. For HR, it is a reason to look beyond the policy file and follow an employee’s working day, including her journey home.

First, a distinction worth keeping clear: this is a set of recommendations, not a change to the PoSH Act. It does not change statutory complaint or inquiry timelines. Its request for an Action Taken Report within two months is addressed to government authorities, not a new blanket filing deadline for private employers.

Some recommendations, such as police response standards, need government action. The workplace recommendations give HR a useful basis for reviewing arrangements with legal, facilities and operations. The practical checks below are our recommendations for that review, not new statutory forms or deadlines.

Can employees actually reach your IC?

Start with a simple exercise. Ask someone to find the correct Internal Committee (IC) contact without help from their manager. Check whether the details are current and whether the contact works. Use a clearly labelled fictional enquiry for testing, never an employee’s confidential complaint.

The PoSH Act already requires employers to provide a safe working environment, regular employee awareness and IC orientation, and facilities for complaints and inquiries. It also requires prominent display of the committee’s constitution order and the penal consequences of sexual harassment, and monitoring of timely IC reports. The advisory renews attention to whether these duties work in practice.

For an organisation with several locations, legal should confirm which committee serves each office or administrative unit. The Act requires ICs at the offices or administrative units covered by its multi-location provision; a central reporting number does not settle that question.

Small workplaces need the correct route too. The Local Committee receives complaints from establishments without an IC because they have fewer than ten workers, and complaints against the employer himself. The advisory’s reference to formal and informal establishments does not mean every small workplace must create its own IC.

Once the route is clear, check the people behind it. Are appointments current? Have new members received orientation? Can they handle evidence and prepare reports? Ungender’s IC training addresses these skills. Choose support around what members need to practise, rather than another attendance certificate.

A hotline or platform can make the committee easier to reach. It cannot replace the appropriate IC or Local Committee’s statutory role.

Who is your training missing?

The advisory calls for awareness and sensitisation for employees regardless of gender. It also discusses consent, stereotypes and respectful conduct. These conversations should not be left to women alone.

Look beyond a company-wide completion percentage. Check who missed the session because they were on a late shift, working in the field, joining through a contractor or unable to access a company device. Use languages and formats people can follow. Ask participants to locate the reporting contact; their answers can tell you what an attendance sheet cannot.

Keep the legal explanation clear. All-gender learning does not make the PoSH Act’s complaint process gender-neutral: the Act defines an “aggrieved woman”. If your organisation has a broader misconduct policy, explain its coverage and reporting route separately.

Managers need practice in receiving a concern without taking over. They should listen, explain where to seek help and arrange the appropriate handoff. They should not decide whether an allegation is true, conduct their own preliminary investigation or make access to the committee depend on their approval.

Ask the learning lead to record missed groups and unanswered questions, with site HR responsible for follow-up.

What happens if the cab does not arrive?

The NHRC recommends adequate workplace security and transport home for women required to work at night, vetting of drivers and security staff, and employer safety protocols for night shifts.

Return to the opening example. Who answers the employee’s call? Who can approve another vehicle? What happens if that person is unavailable? Work through a missed pickup, a shift that runs late or a substituted driver as hypothetical exercises with operations, security and the transport vendor.

Give an operations lead responsibility for resolving the gaps, with HR and procurement involved. Check vendor records against the drivers and security personnel actually assigned. Agree how the organisation will learn about substitutions before deployment, rather than relying only on a general assurance that checks happen.

Legal should separately review the night-work rules applicable to your establishment and location; this advisory is not a complete night-work legal regime. The aim should be to improve the arrangements that allow women to work, rather than make excluding them from opportunities the default response to a safety problem.

Walk the route after dark

Ask facilities to walk from the workplace exit to the pickup point and parking area at the hours people use them. Invite input from women using those spaces, including workers with disabilities. A route that looks fine during a daytime inspection may need a different review after dark.

The advisory recommends lighting, functional washrooms, checks on lights and emergency buttons, functional CCTV and accessible facilities. It also recommends consulting disability organisations when designing infrastructure.

Turn that into specific repair work: which light is broken, who will fix it and who will check it afterwards? If the problem belongs to a property manager or public authority, record whom you contacted and follow up.

Treat CCTV as a privacy decision as well as a maintenance task. The recommendation for functional cameras is not a reason to record private spaces. Review placement, who can view footage, how long it is retained and who handles repairs. Include a privacy review before changing arrangements.

Make the first conversation easier

An employee asking for help may need immediate safety assistance before the organisation has established which formal process applies. Prepare receiving staff to arrange support and explain the available routes without making her repeat a full account to several teams.

The advisory addresses survivor support and referrals, alongside digital abuse such as doxxing, non-consensual intimate imagery and deepfakes. HR and information security should agree who can help preserve relevant material, who may access it and how to assess the appropriate reporting route. Do not ask someone to forward intimate or humiliating material to a group chat as proof.

An online incident does not automatically fall within the IC’s jurisdiction. Seek a case-specific assessment, while keeping immediate support separate from deciding the merits of an allegation.

Conduct’s case-management tools support document and evidence management, timelines, reminders and access controls. Configure those tools around the correct committee structure and confidentiality requirements. Software cannot decide jurisdiction, assess credibility or guarantee legal compliance.

The advisory also recommends education on safe bystander intervention. Its suggestion that a protective law be considered remains a proposal; the advisory does not enact that law.

A reporting detail not to copy into your circular

The advisory refers to enterprises submitting “all enquiry reports” to the District Officer annually. That wording needs care because the Act separates three processes.

An inquiry findings report must go to the employer or, as applicable, the District Officer within ten days of the inquiry’s completion, and be made available to the concerned parties. The committee’s annual report goes to the employer and District Officer. The employer also has a separate duty to report case numbers and disposal in its annual report, or intimate case numbers to the District Officer where no annual report is required.

Do not read the advisory as permission to hold inquiry reports until year-end or circulate confidential case files indiscriminately. The Act restricts public disclosure of complaint and inquiry information. Ask legal to confirm the recipients and requirements before changing your reporting process. The specific provisions are linked in the source notes below.

Give the next step a name and a date

Bring the review to leadership with a short record of what needs fixing, who can fix it and when they will return with evidence. That might be an updated IC contact tested by site HR, an alternative pickup arrangement tested by operations, or a repaired light checked after dark.

Set a review cycle that suits the organisation. This is our recommendation for following through, not the NHRC’s two-month Action Taken Report request to government authorities.

Keep updates on this work separate from identifiable complaint records. Leadership needs to know whether corrective work is overdue; it does not need the details of every allegation to track repairs or training coverage. Nor should fewer complaints become the goal. Check whether people can use the process and whether the organisation responds properly when they do.

Ungender’s enterprise PoSH operating model looks at how policy access, committee support, learning and reporting work together across an organisation. For this review, start with one location. Follow the working day through to the journey home, assign the gaps to people who can address them and check the fixes with the people who use them.

HR leaders reviewing women’s safety across workplaces and shifts can write to contact@ungender.in about partnering with Ungender on PoSH governance.

Penned by Pallavi Pareek, Founder of Ungender and Conduct.

Sources and reading notes

Source links and legal references are collected here so the article can be read without interruptions. The practical exercises and suggested responsibilities above are Ungender’s recommendations, not additional legal requirements.

[1] NHRC advisory on women’s safety at work and public spaces, 23 October 2026. Covering letter and government addressees: PDF page 1. Awareness: section I, PDF pages 2–3; infrastructure and accessibility: section II, PDF pages 4–5; bystander intervention: section III, PDF page 5; police: section IV, PDF pages 5–6; survivor support and digital abuse: sections V–VI, PDF pages 6–7. Night shifts: section VIII(i), PDF page 8. Committees, “all enquiry reports” wording and all-gender awareness: section VIII(ii), PDF page 9. PDF page numbers include the covering letter.

[2] NHRC announcement, 27 October 2026. The announcement date differs from the advisory’s date; both are retained above.

[3] Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. India Code edition marked updated 31 August 2021, retained with the original research. Relevant provisions: section 2(a), statutory complainant definition; sections 4 and 6, IC and Local Committee arrangements; sections 9 and 11, complaints and inquiries; section 13(1), inquiry findings reports; section 16, public-disclosure restrictions; section 19, employer duties; section 21, committee annual reports; section 22, employer reporting. These separate reporting duties explain why the advisory’s annual “all enquiry reports” wording should not be copied without legal review.

[4] Ungender’s enterprise PoSH operating model. Further reading on coordinating workplace PoSH arrangements.

[5] Ungender IC training. Relevant to committee learning on legal foundations, inquiry skills, evidence handling and reporting.

[6] Conduct case management. Product reference for the supporting capabilities described above, not a substitute for committee authority or a guarantee of compliance.