The Code fails to provide ownership or executive information on its website.

The Code’s website domain (“thecode.marketing”), was privately registered on December 4th, 2024.

Further research reveals The Code marketing videos featuring COO Steve Mitchell…

…and CEO Michael Turner:

Steve Mitchell is an MLM veteran who, as per his own website, has promoted NSA, Cabouchon, Euphony, Tiscali, FFI (Fuel Freedom International?), Monavie, Talk Fusion, Visalus, Modere, Melaleuca, Le-Vel, MWR Travel and Velovita.

In April 2024 Mitchell announced he was retiring:

Evidently Mitchell’s retirement didn’t work out.

In a January 25th The Code prelaunch marketing video, Mitchell introduces Michael Turner as follows;

Michael is an honored doctor with a doctorate degree. He’s a certified Dale Carnegie trainer, a hands-on dynamic executive with a proven track record of delivering change and excellence around the globe.

For example, he’s operated companies in sixty-two countries. Launching start-ups and managing billion dollar companies and brands.

He has over twenty-five years experience in people, corporate and field teams. And he’s a board member of Globee International.

Now as a guest presenter on BBC and iTV and Reuters International, I’d also like to welcome him now. My friend and the CEO of The Code, Michael Turner.

As per his LinkedIn profile, Turner is has MLM executive experience through:

  • Nutrition For Life (2003-2005) – North European Sales Manager
  • MannaTech (2006-2009) – Director International Business Development
  • Agel (2009 – 2012) – President EMEA
  • Unicity International (2012-2019) – Vice President Europe, Middle East and North Africa, and Vice President EURASIA
  • Jeunesse (2019-2023) – General Manager

Turner has been a board member of Globee International since January 2023.

On its website, Globee International claims to be an “international agency” that “focuses its efforts on building broad international coalitions in support of Ukraine”.

Turner claims “full professional proficiency” in Russian. Turner’s honorary degree was issued by Ukraine’s Kharkov National University in August 2016.

At the time Turner was working for US MLM company Unicity International, which is a bit odd.

Another name we can attach to The Code is Alfredo Bala:

Bala, who also goes by Al Bala, appears as a “guest” and “trainer” in The Code marketing videos.

Bala was CEO of MannaTech until April 2024. That said, as late as January 2025 Bala was still appearing at Mannatech marketing events:

If Bala has any additional involvement or ties to The Code, this is being withheld.

As per their respective social media profiles:

  • Steve Mitchell is based out of Spain
  • Michael Turner is based out of the UK
  • Alfredo Bala is based out of the US

The Code fails to provide a corporate address on its website. The Code’s website Termsn and Conditions suggests The Code is run through a Seychelles shell company;

he Code, Marketing and Mentoring Platform is registered in accordance with the Companies Act of the Seychelles with the appropriate license issued by the Seychelles Licensing Authority (SLA) as stated by the Licenses Act 1986.

Seychelles is a tax-haven with no known MLM regulation. The Code being registered through a Seychelles shell company raises an immediate red flag.

As always, if an MLM company is not openly upfront about who is running or owns it, think long and hard about joining and/or handing over any money.

The Code’s Products

The Code has no retailable products or services.

Affiliates are only able to market The Code affiliate membership itself.

The Code’s Compensation Plan

The Code affiliates sign up and pay subscription fees:

  • The Code subscription is 49 EUR every 30 days or 300 EUR every 365 days
  • access to Xtera appears to cost 100 EUR

The MLM side of The Code pays on recruitment of affiliate investors who also pay the above subscription/access fees.

Withdrawal Restrictions

The Code only pays 50% of affiliate withdrawal requests upfront.

The other 50% is drip-fed at a rate of 10% each month till paid out over ten months.

The Code Affiliate Ranks

There are eleven affiliate ranks within The Code’s compensation plan.

Along with their respective qualification criteria, they are as follows:

  1. Affiliate – sign up as a The Code affiliate and pay subscription/access fees
  2. Starter – generate 500 EUR in subscription/access fee volume on both sides of your binary team
  3. Builder – generate 7000 EUR in subscription/access fee volume on the weaker side of your binary team, 10,000 EUR on the stronger side, and have one Starter or higher ranked affiliate on both sides of the binary team
  4. Sapphire – generate 15,000 EUR in subscription/access fee volume on the weaker side of your binary team, 25,000 EUR on the stronger side and have one Builder or higher ranked affiliate on both sides of the binary team
  5. Ruby – generate 30,000 EUR in subscription/access fee volume on the weaker side of your binary team, 45,000 EUR on the stronger side and have one Sapphire or higher ranked affiliate on both sides of the binary team
  6. Emerald – generate 70,000 EUR in subscription/access fee volume on the weaker side of your binary team, 100,000 EUR on the stronger side and have one Ruby or higher ranked affiliate on both sides of the binary team
  7. Diamond – generate 150,000 EUR in subscription/access fee volume on the weaker side of your binary team, 250,000 EUR on the stronger side and have one Emerald or higher ranked affiliate on both sides of the binary team
  8. Double Diamond – generate 400,000 EUR in subscription/access fee volume on the weaker side of your binary team, 600,000 EUR on the stronger side and have one Diamond or higher ranked affiliate on both sides of the binary team
  9. Triple Diamond – generate 1,000,000 EUR in subscription/access fee volume on the weaker side of your binary team, 1,500,000 EUR on the stronger side and have one Double Diamond or higher ranked affiliate on both sides of the binary team
  10. Crown Diamond – generate 2,500,000 EUR in subscription/access fee volume on the weaker side of your binary team, 3,500,000 EUR on the stronger side and have one Triple Diamond or higher ranked affiliate on both sides of the binary team
  11. Presidential Diamond – generate 4,000,000 EUR in subscription/access fee volume on the weaker side of your binary team, 6,000,000 EUR on the stronger side and have one Crown Diamond or higher ranked affiliate on both sides of the binary team

Referral Commissions

The Code subscription fee payments generate a 20% referral commission.

100 EUR Xtera share investments pay a 6% referral commission.

Residual Commissions

The Code pays residual commissions via a binary compensation structure.

A binary compensation structure places an affiliate at the top of a binary team, split into two sides (left and right):

The first level of the binary team houses two positions. The second level of the binary team is generated by splitting these first two positions into another two positions each (4 positions).

Subsequent levels of the binary team are generated as required, with each new level housing twice as many positions as the previous level.

Positions in the binary team are filled via direct and indirect recruitment of affiliates.

At the end of a residual commission pay-period, The Code tallies up new Xtera share investment volume across the binary team.

Residual commissions are paid as 8% of Xtera share investment on the weaker binary team side.

Once paid out on, volume is matched against the stronger binary team side and flushed. Any leftover volume on the stronger binary team side carries over.

Infinity Bonus

The Infinity Bonus pays an undisclosed percentage on The Code subscription fee payments and Xtera share investment.

  • unranked, Starter and Builder affiliates earn the Infinity Bonus on up to 25,000 recruited affiliates
  • Sapphire affiliates earn the Infinity Bonus on up to 50,000 recruited affiliates
  • Ruby affiliates earn the Infinity Bonus on up to 75,000 recruited affiliates
  • Emerald affiliates earn the Infinity Bonus on up to 150,000 recruited affiliates
  • Diamond affiliates earn the Infinity Bonus on up to 250,000 recruited affiliates
  • Double Diamond affiliates earn the Infinity Bonus on up to 300,000 recruited affiliates
  • Triple Diamond affiliates earn the Infinity Bonus on up to 350,000 recruited affiliates
  • Crown Diamond affiliates earn the Infinity Bonus on up to 400,000 recruited affiliates
  • Presidential Diamond affiliates earn the Infinity Bonus on all recruited affiliates who are recruited after them

Note that recruited affiliates for the Infinity Bonus can be directly or indirectly recruited. All recruits after the qualifying affiliate joins are counted.

Leadership Pool

The Code takes 10% of monthly Xtera share investment and places it into a Leadership Pool.

The Leadership Pool is split between Sapphire and higher ranked affiliates across eight 1.25% smaller pools.

Rank Achievement Bonus

The Code rewards affiliates for qualifying at Sapphire and higher with the following one-time Rank Achievement Bonuses:

  • qualify at Sapphire and receive a “Sapphire Trip” valued at 500 EUR
  • qualify at Ruby and receive 1000 EUR
  • qualify at Emerald and receive an “Emerald Trip” valued at 2500 EUR
  • qualify at Diamond and receive a “luxury watch” valued at 6500 EUR
  • qualify at Double Diamond and receive 50,000 EUR
  • qualify at Triple Diamond and receive a “super car” valued at 200,000 EUR
  • qualify at Crown Diamond and receive “property” valued at 500,000 EUR
  • qualify at Presidential Diamond and receive 1,000,000 EUR

Joining The Code

The Code affiliate membership is via subscription:

  1. 49 EUR every 30 days; or
  2. 300 EUR for 365 days

Full participation in the in The Code’s attached income opportunity requires a 100 EUR Xtera access fee and minimum 100 EUR investment in Xtera shares.

The Code Conclusion

Although it’s presented as a third-party in The Code marketing…

…Xtera is likely being run by the same people running The Code.

  • The Code’s website domain was registered in December 2024, Xtera’s website domain (“xtera.org”), was privately registered in January 2025
  • The Code’s and Xtera’s websites are both built on the “jswstheme” WordPress theme

While Steve Mitchell and Michael Turner are presented as The Code executives, the scheme is otherwise set up as a typical Dubai MLM Ponzi.

From The Code’s website Terms and Conditions:

The Code, Marketing and Mentoring Platform operates in select jurisdictions. Our services are not available in the following countries and territories:

  • United States of America (USA)
  • Gulf Cooperation Council (GCC) countries (including Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates)

There’s nothing illegal about offering returns on shares in the US. Provided of course a company registers with the SEC and files timely audited financial reports.

Scammers running fraudulent investment schemes will typically block US residents in an attempt to stay under the regulatory radar. In the SEC, the US has the most active securities regulator in the world.

There’s no reason to block the UAE unless The Code has an undisclosed tie to the country. With Dubai being the MLM crime capital of the world, my money is there.

Michael Turner being fluent in Russian and having ties to Ukraine fits in with Russian/Ukrainian scammers operating out of Dubai.

This is of course speculation on my part. Call it an educated guess having seen this eastern European scam template over and over again.

Failure to register with the SEC would constitute securities fraud for US resident investment into Xtera shares. The same is true for any jurisdiction with a regulated financial market.

The Code fails to provide evidence it has registered its Xtera share scheme with financial regulators in any jurisdiction.

As of February 2025, SimilarWeb was tracking

  • 60% of The Code’s website traffic originating from Nigeria, followed by 40% from Colombia
  • 100% of Xtera’s website traffic originating from the US

As it stands, the only verifiable source entering the The Code is new Xtera share investment.

Using new Xtera share investment to pay ROI withdrawals would make The Code a Ponzi scheme.

Additionally, with nothing marketed or sold to retail customers, the MLM side of The Code operates as a pyramid scheme.

As with all MLM Ponzi schemes, once affiliate recruitment dries up so too will new investment.

This will starve The Code of ROI revenue, eventually prompting a collapse.

The math behind behind Ponzi schemes guarantees that when they collapse, the majority of participants lose money.

With decades of MLM experience between them, Steve Mitchell, Michael Turner and Al Bala all definitely know better.