What an Inspector Checks First
The inspection notice arrived on a Thursday for the following week. The compliance team spent the weekend printing policies and framing certificates. On the day, the inspector asked for the internal committee order, the last year of awareness programmes, and the complaint register. Two of those three did not exist in the form the inspector expected. The framed certificates on the wall were not what was being checked.
This is what an inspector checks first. Not the polished surface, but the paper trail that proves the process is real. If you know what that trail looks like, you can tell whether your own workplace would pass before anyone comes to look.
The order that constitutes the committee
The first thing an inspector looks for is the document that proves your internal committee exists as a properly constituted body. That means the order, notification or written record that names the members, their roles, and the date it took effect. A committee that exists only in practice, with members who know who they are but no document that says so, does not exist for inspection purposes.
Within that, the inspector looks at the composition. The law sets out who should be on the committee, including a presiding officer, and it expects an external member, someone from outside the organisation, with the relevant experience. The inspector will check that the external member is named, is genuinely external, and is actually involved, not just listed. A committee that has never met its external member is a committee with a gap.
The awareness and training record
The second thing is the record of awareness. The law expects the employer to run programmes and to make employees aware of the process. The inspector is not looking for a single induction slide. They are looking for evidence that awareness has been built and kept up.
- Records of the programmes run, with dates, and who attended.
- The material used, so the inspector can see what people were told.
- Evidence that the process itself was communicated, not only the policy.
- Something showing that new joiners are covered, not just the people who were there when the programme started.
A company that ran one session three years ago and nothing since has a record that stops, and the stop is visible. Regular, dated sessions tell a different story, and that story is what the inspector is reading.
The complaint register and the trail
The third thing is the trail of actual complaints. The inspector looks for a register, or the equivalent, that records what came in and what happened to it. This is the part that catches companies out, because it is where the paper and the practice most often disagree.
A register that shows no complaints at all is not automatically a problem, but it invites a question: is there genuinely nothing, or is nothing being recorded? A register that shows complaints with gaps in the trail, no dates for the inquiry, no record of the outcome, is worse, because it shows the process started and was not followed through.
The inspector will also look at whether complaints were resolved within the timeline, and whether the outcomes were acted on. A complaint that was investigated but never closed, or closed with no record of what was decided, is a loose end that the inspector will pull.
What is on the wall versus what is in the file
Companies often prepare the visible things: the policy printed and bound, the certificate framed, the committee names on a notice board. These matter, and their absence would be noticed, but they are not the core of the inspection. The core is the file.
The file shows whether the process has actually been running. Policies can be written in a week. A year of dated programmes, a register of complaints with complete trails, a committee that has met and minuted its meetings: these cannot be produced quickly, because they are evidence of what happened over time. That is exactly why the inspector looks for them first.
What we look for before an inspection
When we prepare a client for a POSH inspection, we run the same checks the inspector will run, in the same order.
- Is there a current order constituting the committee, with names, roles, the external member and the date?
- Has the external member actually been involved, and is there a record of it?
- Are there dated awareness programmes, with material and attendance, covering new joiners?
- Is there a complaint register, and does each entry have a complete trail with dates and outcomes?
- Do the inquiries fit the statutory timeline?
- Is the policy the current version, and does it match what the committee actually does?
Where the answer is no, the fix is not to create a document the night before. It is to build the process so that the trail exists because the work was done. A trail that is invented for an inspection is easy to spot and hard to defend.
The point of the inspection
An inspection is not a test of how well you can present. It is a check on whether the workplace has a process that protects people and follows the law. The surface a company shows is only the first few seconds of the visit. The rest of the time is spent in the file, reading what actually happened.
A workplace that is genuinely running its process will pass an inspection without special preparation, because the trail is already there. A workplace that is not will struggle, no matter how well the wall is decorated, because the file tells the truth. The framed certificate proves a decision was made once. The register proves the decision is still being honoured, month after month, complaint after complaint.
There is a useful test in this. Before any notice arrives, ask yourself a single question: if an inspector sat down tomorrow and read only the file, without meeting a single person, would the file show a workplace that takes this seriously? If the honest answer is no, you already know what the visit will find, and you have time to change it.
We do not guess. We investigate. When we audit a POSH setup, we read the file the way an inspector would, and we tell the client what it says. That is a harder conversation than admiring the certificates, and a far more useful one.