Not on that basis alone. Someone who primarily supervises employees who are neither professional nor supervisory is treated as a first-line supervisor rather than a manager. The stronger claim for a hotel general manager is usually management of an essential function of the organization rather than management of personnel.
Count what he controls, not how many people report to him
The distinction frustrates people who genuinely do run a business, and it is worth understanding rather than arguing with. Personnel management is measured by the character of the employees supervised, so a general manager with a large but non-professional crew can fall outside it while a director with three analysts falls inside. Function management asks a different question: does the employee manage an essential function of the organization, operate at a senior level within the hierarchy or with respect to that function, and exercise discretion over its day-to-day operations.
For Bertrand that means the petition should identify the function precisely, say revenue management and distribution across the group's properties, show that the function exists independently of him, and show that he sets policy for it rather than executing someone else's. Job titles carry no weight in either analysis, and a chart submitted without a description of what each box does invites the weaker reading.