No. Explain the applicant’s actual principal duties and authority. Travel frequency is context, not a role qualification.
Identify the decisions behind the visits
Distinguish oversight from personal operational delivery. A person attending many meetings is not automatically performing primarily managerial or executive work.
The regulation asks whether the employee primarily manages the organization or a department, supervises and controls the work of other supervisory or professional employees or manages an essential function, has authority over hiring and firing, and exercises discretion over day-to-day operations. Executive capacity is described in terms of directing the organization or a major component of it, setting goals and policies, exercising wide discretion, and receiving only general supervision. A first review should produce three separate findings: the companies have the required relationship, the employee completed qualifying work abroad in the relevant period, and the proposed position is managerial or executive in substance. Most companies already hold a document listing who may authorise spending, hiring and terminations at each level, and that document usually answers the managerial-capacity question faster than a role description written for the file.