Physical meeting
The right of a whistleblower to meet a competent person at the reporting channel in person within a reasonable period, at their own request, in order to make a report orally.
A physical meeting refers to the statutory right of a whistleblower to submit a report not only in writing or by telephone but, at their own request, during an in-person meeting with a member of staff responsible for receiving reports. Under Section 16(3) of the German Whistleblower Protection Act (HinSchG) for internal reporting channels and Section 27(3) HinSchG for external reporting channels, the reporting channel is obliged to make such a meeting possible within a reasonable period. At the whistleblower's request, the meeting may also be conducted by video and audio transmission.
The physical meeting is a particular form of oral report. While reporting channels are typically designed for written or telephone submissions, the HinSchG grants the whistleblower an enforceable right to explain their concern in a direct conversation. This serves both full clarification of the facts and the protection of trust: complex or sensitive matters can often be described more precisely and comprehensibly in a personal exchange than in a form. The Act does not set a fixed number of days for arranging the meeting, but the period must be calculated so that the report can be addressed promptly.
Where a meeting takes place, the general documentation duties under Section 11 HinSchG apply: with the whistleblower's consent, the conversation may be documented by a permanently retrievable audio recording or by a complete and accurate written record. The whistleblower must be given the opportunity to check the record, correct it where appropriate and confirm it with their signature. The duty of confidentiality remains fully in force during a physical meeting as well; the whistleblower's identity may be disclosed only under the narrow conditions set out in the Act.
Legal Basis
Section 16(3), Section 27(3), Section 11 HinSchG
Practical Example
An employee of a mid-sized company suspects serious billing manipulation but does not feel comfortable entering the details through the anonymous online reporting portal. He asks the internal reporting channel by e-mail for a personal conversation. The compliance officer acknowledges receipt within seven days and offers an appointment in a neutral meeting room within two weeks; alternatively, she offers a video call. During the meeting she records the facts, presents the record to the whistleblower for review and signature, and ensures that only she has access to the identity data.