Not by itself. Assess the actual authority and duties, including whether the person primarily manages rather than performs operating work.
Describe the real decisions
A signature on a routine purchase and responsibility for an essential function are not automatically the same thing.
The first route asks whether the person supervises and controls the work of other supervisory, professional or managerial employees, and has authority over hiring, firing and other personnel actions or, where nobody is supervised, over daily operations. A carrier's dispatch and freight-acceptance function is plainly essential, and a manager who decides which loads are taken, negotiates owner-operator contracts, sets rates and controls the function's budget is managing it, even though the dispatchers are clerical employees and the drivers are contractors. 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. The file still needs to show genuine qualifying employment, a qualifying corporate relationship, and that the U.S. role is primarily managerial or executive, with the ownership stake disclosed and assessed on its own facts rather than treated as an automatic bar.