Social Economy Glossary | Root & Branch

The Trap of the 'False Friend'

In the Social and Solidarity Economy (SSE), a direct translation is often a structural error. Legal concepts in the Anglosphere (Common Law) rarely map perfectly onto the Romance-speaking world (Civil Law). A 'Non-Profit' in New York operates under a negative constraint (non-distribution), whereas a Société coopérative d'intérêt collectif (SCIC) in France operates under a positive mandate (social utility).

Confusing the two isn't just a linguistic slip; it is a governance risk. This glossary acts as a navigator for these 'untranslatables', covering English, French, Spanish, Catalan, Italian, and Portuguese.

Navigating Legal Distance

By mapping these distances, we ensure that practitioners can build cross-border partnerships that are legally robust and theoretically sound. This resource connects the 19th-century insights of Proudhon with modern frameworks like Ostrom’s polycentric governance and Feminist Economics' social reproduction, treating language itself as a shared protocol for transition.

The Master Key: A Field Guide to Untranslatables

Concept	Translation Logic	Description and Narrative Context
Asset Lock	Contrasts with: Réserve impartageable (FR) / Riserva indivisibile (IT).	In the UK and US, an Asset Lock is a negative constraint preventing the distribution of residual assets. In the Continental tradition, this is framed positively as 'Indivisibility'. The nuance is critical: 'Indivisibility' asserts that the capital belongs to the movement itself – a socialisation of wealth over time – whereas a 'Lock' merely restricts the current owners.
Ateneu (Cooperatiu)	Specific to Catalonia.	An Ateneu is not just a 'hub'; it is a secular, working-class institution for popular education. In modern Catalan policy, Ateneus Cooperatius are state-funded but community-managed infrastructures that incubate cooperatives territorially. It represents a public-social partnership model distinct from the private business incubator.
Aubaine	Borrowed from: Droit d'aubaine (FR).	Often mistranslated as 'windfall'. I retain the French loan word to preserve its political teeth. Originally the feudal right of a sovereign to seize the estate of a foreigner (escheat), Proudhon used it to describe capital's systemic power to appropriate the collective force of labour without compensation. Unlike 'windfall', which implies luck, aubaine signifies a legalistic seizure of value.
Autogestion	Borrowed from: Autogestion (FR) / Autogestión (ES).	In English, 'self-management' often sounds like a soft HR strategy for efficient teams. I use the Romance term to signal its militant roots in the Empresa Recuperada movement. It describes a political project where the distinction between capital and labour is eliminated entirely through direct workers' control.
Banal / Banalité	Reclaimed from feudal etymology.	In modern English, 'Banal' means boring. I reclaim the Proudhonian usage: banalité referred to feudal infrastructure (mills, ovens) that was required to be open for common use by tenants. I argue that modern digital infrastructures and utilities are the new 'banalities' – resources that must remain common and accessible.
Buen Vivir	Borrowed from: Buen Vivir (ES) / Sumak Kawsay (Quechua).	An Andean concept enshrined in the constitutions of Ecuador and Bolivia. It rejects 'development' (linear economic growth) in favour of 'living well' in community. I include it as it provides the legal framework for granting rights to nature, shifting the goal of the social economy from sustainable growth to stewardship.
Collective Force	Translates: Force collective (FR) / Fuerza colectiva (ES).	The surplus productive power generated by the convergence and organisation of individuals, which exceeds the sum of their individual efforts. I centre this concept to refute the capitalist theory of value. The employer pays for individual labour but appropriates the collective force for free; reclaiming this force is the primary task of the social economy.
Consiglio di Fabbrica	Specific to Italian workers' movement.	Factory Council. A governance structure (Gramsci/Turin) that differs from a Trade Union. While unions negotiate wages within the market, the Council aims to manage production itself. In modern 'Recovered Factories', this structure replaces the Board of Directors.
Distretto (DES)	Borrowed from: Distretto di Economia Solidale (IT).	'Solidarity Economy District'. An Italian legal framework where SSE organisations in a specific territory network their supply chains to create a closed circuit of value. Unlike a 'cluster' (which is competitive), a DES is cooperative. It relies on the 'territorial preferential option' – sourcing locally not for efficiency, but to build local political power.
Empresa Recuperada	Specific to Argentina/Latin America.	Recovered Enterprise. A term emerging from the Argentine crisis (2001). Unlike a 'buyout', which implies a financial transaction, 'recuperation' implies a political act of reclaiming productive assets abandoned by capital. Workers occupy the plant and restart production under self-management.
Fiduciary Duty	Contrasts with: Intérêt Collectif (FR).	The legal obligation to act in the best interest of another. In the Anglosphere, this is almost exclusively interpreted as maximising shareholder value. I view this as a primary barrier to transition, and I contrast it with the Civil Law concept of 'Collective Interest', which legally prioritises multi-stakeholder benefit over profit.
Intérêt Collectif	Borrowed from: Intérêt Collectif (FR) / Interesse Collettivo (IT).	A codified legal duty in French (SCIC) and Italian (Law 381) law that requires an organisation to serve a multi-stakeholder community (workers, users, volunteers). Unlike Fiduciary Duty, which narrows the focus to shareholders, this provides a legal shield for prioritising social mission.
Isomorphism	Translates: Isomorphisme (Sociology).	The tendency of social economy organisations to resemble capitalist firms over time to gain legitimacy. I use this to diagnose 'mission drift' – such as when a mutual bank begins to rely on the same risk-scoring logic as a commercial bank, effectively erasing its own social utility.
Minga	Borrowed from: South America.	A term for collective work for the benefit of the community. Unlike 'volunteering', which is individual and optional, a Minga is a reciprocal obligation of community membership. I use it to highlight the distance between 'charity' (vertical) and 'mutual aid' (horizontal).
Mutuum	Borrowed from: Latin / Proudhon.	A loan of fungible goods where the borrower returns the exact value without interest. In my work on social finance, I treat the mutuum as the ancestor of zero-interest lending, rejecting the 'time-value of money' in favour of simple reciprocity.
Orçamento Participativo	Borrowed from: Portuguese (Brazil).	Participatory Budgeting. Originating in Porto Alegre. It is not merely 'consultation'; it is a binding process where citizens directly vote on the allocation of municipal funds. I use the Portuguese term to remind practitioners of its radical roots, distinct from the diluted versions often applied in the UK.
Popular Economy	Translates: Economía popular (ES) / Économie populaire (FR).	Activities undertaken by marginalised classes to ensure their own reproduction. I refuse the English 'Informal Economy', which is a statistical pejorative. Economía Popular is a political identity of survival and resistance that predates and bypasses formal state structures.
Precarity	Translates: Précarité (FR) / Precariedad (ES).	In standard English, 'precariousness' is an adjective describing a risky situation. In the European Social Economy, 'Precarity' is a noun describing a structural class condition – the loss of predictability and security in labour. It defines the subject of the new social economy (the 'precariat') distinct from the industrial proletariat.
Reciprocity	Translates: Reciprocitat (CA) / Réciprocité (FR).	Exchange based on mutual social obligation. In my analysis of the Catalan Reciprocitat, I argue that this is the primary engine of the commons. It is distinct from market exchange (contractual) and state redistribution (bureaucratic).
Social Reproduction	Translates: Reproduction sociale (FR).	The work required to maintain and reproduce the workforce (care, cooking, education). I argue that standard finance ignores this as an 'externality', while the social economy posits it as the foundational economy upon which all market value rests.
Social Utility	Translates: Utilité sociale (FR) / Utilità sociale (IT).	A positive legal status in Civil Law. Unlike the 'Non-Profit' – which is defined by what it cannot do – the Social Utility model allows for surplus and distribution, provided the primary aim remains the service of the community.
Solidarity Finance	Translates: Finance solidaire (FR).	Financial instruments where the goal is social cohesion rather than ROI. Distinct from 'Impact Investing', which implies a financial return. It includes 'sharing' mechanisms (where savers donate part of their interest) and 'proximity' mechanisms (local investment circuits).
Terroir	Borrowed from: Terroir (FR) / Terrer (CA).	Strictly untranslatable. In SSE agriculture, it signifies that a product cannot be delocalised because its value is tied to specific land, climate, and community knowledge. It is the antithesis of the commodity. I use it to argue against the standardisation of food systems.
Third Sector	Contrasts with: Économie Sociale (FR).	In the UK/US, 'Third Sector' implies non-profits filling gaps left by the State (First) and Market (Second). In the Continental tradition, Économie Sociale refers to productive enterprises (co-ops, mutuals) that actively compete in the market but democratise it. One fills gaps; the other seeks to replace the system.
Titre Participatif	Borrowed from: Titre Participatif (FR).	'Participating Security'. A specific French financial instrument that allows cooperatives to raise equity without giving up voting rights. It solves the conundrum of how labour can hire capital without the capital appropriating the Collective Force of the workers.