At the moment the money must be listed in the unpaid wages register or the unpaid bonus register. After 3 years it needs to be transferred to labour welfare fund
This is not under factory act but under minimum wages act and the state labour welfare fund acts. In the end the definition in these acts will apply. Most states define a manager. If not then he must have specifically managerial rule and not just any one called a manager. He must not be doing work but only supervising.
So if these people are sales guys than most probably they are not managers