Mar 23, 2010 11:11
14 yrs ago
39 viewers *
Czech term

Jednatel, prokurista

Not for points Czech to English Law/Patents Law (general)
Marta Chromá in her dictionary translates "prokurista" alternatively as "proctor, procurator or chief/confidential clerk" and "Company Secretary" as "jednatel." Although it is difficult to make a perfect match between the members of corporate bodies in Czech and English-speaking jurisdictions, I do not particularly like this choice for various reasons, and personally prefer to use "Director" or "Managing Director" for "jednatel" and "Company Secretary" for "prokurista." What are your preferences regarding "prokurista" and "jednatel"?
References
procurator

Discussion

Gerry Vickers Mar 23, 2010:
Jednatel can also be 'authorised representative' - there is no direct equivalent in UK English at least, and this covers all bases.

Proposed translations

1 hr
Selected

executive officer, authorized signatory

I generally use "executive officer" and "authorized signatory", which I think will be reasonably clear to any English speaker, but the situation is complicated not only because the Czech terms don't have real equivalents in the Anglosphere, but also because typical org charts and titles also differ from one English-speaking country to another. It might be best just to follow Trade Links or other published legal translations even if the terms there turn out to be a little "Czenglish", because no really definitive rendering exists.
Note from asker:
Thank you for your answer. I mentioned my misgivings about the word "executive" above, but I agree that your solution is self-explanatory and certainly clear enough.
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7 mins

executive - procurator (responsible proxy)

z advokátní praxe - jednatel může ale nemusí být ředitel

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Note added at 8 mins (2010-03-23 11:19:19 GMT)
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popř. the Executive
Note from asker:
Thank you for your response. My hesitation to use the word "executive" stems from the fact that authorized representatives (aka "statutory organs" :-)) of UK and US corporations are simply "Directors" and from the fact that the word "executive" implies (in my mind) a limitation of the scope of jednatel's duties to the management of day-to-day running of the company. This is why I find it more convenient to use "Chief Executive Officer" for ředitel.
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77 days

Executive (officer); Attorney-in-fact

Prokurista = attorney-in-fact: this translation is used by Google Finance service, sometimes Reuters and other services. Direct translation of original prokurista or German prokurist is sometimes added in brackets. As for jednatel: translation to executive/executive officer is the one I use already for few years based on many local examples from lawyers/consultants from "big four".
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Reference comments

9 mins
Reference:

procurator

A member of the board of directors or supervisory board, procurator (in Czech “prokurista”)
or broker of an investment firm may only be a person who is not a Deputy or Senator of
Parliament, a member of the Government,…..


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Note added at 19 mins (2010-03-23 11:30:54 GMT)
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a general proxy (prokurista) of a limited liability or joint-stock company;
http://www.allenovery.com/AOWeb/binaries/23761.pdf
If the foreign national is to be registered in the Czech Commercial Register as
the statutory representative of an entity registered in the Czech Republic, as the

managing director ("jednatel")

of a Czech limited-liability company, as a member
of the board of directors of a joint-stock company or as a branch manager, then
no work permit is needed and the long-term visa is applied for on the basis of
his/her appointment
http://www.pwc.com/en_CZ/cz/studie-analyzy/foreign-nations-w...
Company Executive, I agree, is also used for 'jednatel'
Example sentence:

.

Note from asker:
I like your suggestion best, so far. I am not really quite sure about "Company Secretary" but it appears to me that the scope of powers and duties given to "prokurista" and "Company Secretary" are somewhat similar as is the relationship between prokurista and jednatel on the one and Director and Company Secretary on the other hand.
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