The number of subordinates is not the test. What matters is whether her duties are primarily managerial or executive, which can be shown either through the seniority of those she supervises or by managing an essential function.
Two routes to the managerial finding
Hypothetical example: Supervising employees who are themselves supervisory, professional or managerial is one accepted pattern, and four warehouse staff will not usually satisfy it because first-line supervision of non-professional workers is generally excluded. The other pattern is the function manager: a person who manages an essential function of the organization at a senior level, with discretion over its day-to-day operations, even without direct reports of the required seniority. Renee's file is stronger if it identifies the function precisely, shows that it is essential to the business, and demonstrates her authority over its budget, policies and outcomes. Either way, the analysis returns to how her time is actually spent, so the duty description and the staffing plan have to agree with each other.
Start by producing a reporting chart, duty percentages and evidence of authority over budget, policy or personnel. Hypothetical example: A specialty-paper distributor wants its regional director to lead a small U.S. branch. Her title is not decisive; payroll and the staffing plan must show who performs sales, warehousing and administration while she directs the function. If she will personally carry most operational tasks, the claimed managerial role may not fit yet.
Use current payroll, not projected titles, to show the people and functions being directed. A future organization chart explains growth but cannot erase present operational duties.