Not by title alone. Explain their actual roles and the applicant’s own managerial or executive responsibilities under the applicable requirements.
Look through every layer of the chart
Identify what authority the subordinate managers exercise and what work they perform. Nominal management layers cannot replace evidence of the actual organization and the applicant’s qualifying duties. Test each subordinate title against a document that would only exist if the authority were real.
Someone who genuinely manages staff leaves traces: a signed offer of employment, an approved roster, a completed and signed performance review, a disciplinary record, an authorised leave approval. Someone who coordinates leaves different traces — meeting notes, task lists, escalation messages — and those are worth producing too, accurately labelled, because the analysis wants the structure as it operates rather than a flattering version of it. Hypothetical example: a regional lead in an animal-health distribution business supervises four territory representatives; the personnel file shows their offers were signed by a head-office director, while the lead sets call plans and approves expenses to a fixed limit.
That is a describable role, and describing it accurately serves better than calling it managerial and hoping the word carries. The applicant’s own qualifying duties still need their own evidence, and one continuous qualifying year abroad within the preceding three remains a separate requirement.