No. Assess the actual primary duties and authority. A leadership label does not establish that the person manages rather than principally performs the work.
Describe the balance using genuine responsibilities
Identify operating tasks retained and the support available. A function manager needs senior authority over an essential function, and first-line supervision of nonprofessionals alone is insufficient.
A person who directs thirty dock workers and drivers feels unmistakably managerial in ordinary language, yet the definition specifically excludes first-line supervision of employees who are not professionals unless the supervised staff are themselves supervisory. For a training operations director this means showing what the person directs: which programmes and instructors, what budget authority, who is hired and fired on their decision, what discretion exists over scheduling, pricing and accreditation. Supervising professional employees supports the showing, while a first-line supervisor of routine work does not qualify merely by holding a supervisory title, and the classification looks at whether the applicant manages an organisation, department, subdivision, function, or component. Choose the route the records actually support rather than the one that sounds more impressive, and confirm separately that the qualifying parent, branch, subsidiary or affiliate relationship exists, since no amount of duty evidence rescues a case where it does not.