The Code fails to supply possession or govt data on its web site.
The Code’s web site area (“thecode.advertising and marketing”), was privately registered on December 4th, 2024.
Additional analysis reveals The Code advertising and marketing movies that includes COO Steve Mitchell…
…and CEO Michael Turner:
Steve Mitchell is an MLM veteran who, as per his personal web site, has promoted NSA, Cabouchon, Euphony, Tiscali, FFI (Gas Freedom Worldwide?), Monavie, Discuss Fusion, Visalus, Modere, Melaleuca, Le-Vel, MWR Journey and Velovita.
In April 2024 Mitchell introduced he was retiring:
Evidently Mitchell’s retirement didn’t work out.
In a January twenty fifth The Code prelaunch advertising and marketing video, Mitchell introduces Michael Turner as follows;
Michael is an honored physician with a doctorate diploma. He’s an authorized Dale Carnegie coach, a hands-on dynamic govt with a confirmed monitor report of delivering change and excellence across the globe.
For instance, he’s operated corporations in sixty-two nations. Launching start-ups and managing billion greenback corporations and types.
He has over twenty-five years expertise in individuals, company and area groups. And he’s a board member of Globee Worldwide.
Now as a visitor presenter on BBC and iTV and Reuters Worldwide, I’d additionally wish to welcome him now. My pal and the CEO of The Code, Michael Turner.
As per his LinkedIn profile, Turner is has MLM govt expertise by:
- Vitamin For Life (2003-2005) – North European Gross sales Supervisor
- MannaTech (2006-2009) – Director Worldwide Enterprise Growth
- Agel (2009 – 2012) – President EMEA
- Unicity Worldwide (2012-2019) – Vice President Europe, Center East and North Africa, and Vice President EURASIA
- Jeunesse (2019-2023) – Common Supervisor
Turner has been a board member of Globee Worldwide since January 2023.
On its web site, Globee Worldwide claims to be an “worldwide company” that “focuses its efforts on constructing broad worldwide coalitions in assist of Ukraine”.
Turner claims “full skilled proficiency” in Russian. Turner’s honorary diploma was issued by Ukraine’s Kharkov Nationwide College in August 2016.
On the time Turner was working for US MLM firm Unicity Worldwide, which is a bit odd.
One other identify we are able to connect to The Code is Alfredo Bala:
Bala, who additionally goes by Al Bala, seems as a “visitor” and “coach” in The Code advertising and marketing movies.
Bala was CEO of MannaTech till April 2024. That mentioned, as late as January 2025 Bala was nonetheless showing at Mannatech advertising and marketing occasions:
If Bala has any extra involvement or ties to The Code, that is being withheld.
As per their respective social media profiles:
- Steve Mitchell relies out of Spain
- Michael Turner relies out of the UK
- Alfredo Bala relies out of the US
The Code fails to supply a company handle on its web site. The Code’s web site Termsn and Situations suggests The Code is run by a Seychelles shell firm;
he Code, Advertising and marketing and Mentoring Platform is registered in accordance with the Firms Act of the Seychelles with the suitable license issued by the Seychelles Licensing Authority (SLA) as said by the Licenses Act 1986.
Seychelles is a tax-haven with no recognized MLM regulation. The Code being registered by a Seychelles shell firm raises a direct crimson flag.
As at all times, if an MLM firm just isn’t brazenly upfront about who’s working or owns it, suppose lengthy and arduous about becoming a member of and/or handing over any cash.
The Code’s Merchandise
The Code has no retailable services or products.
Associates are solely in a position to market The Code affiliate membership itself.
The Code’s Compensation Plan
The Code associates join and pay subscription charges:
- The Code subscription is 49 EUR each 30 days or 300 EUR each one year
- entry to Xtera seems to value 100 EUR
The MLM facet of The Code pays on recruitment of affiliate buyers who additionally pay the above subscription/entry charges.
Withdrawal Restrictions
The Code solely pays 50% of affiliate withdrawal requests upfront.
The opposite 50% is drip-fed at a price of 10% every month until paid out over ten months.
The Code Affiliate Ranks
There are eleven affiliate ranks inside The Code’s compensation plan.
Together with their respective qualification standards, they’re as follows:
- Affiliate – join as a The Code affiliate and pay subscription/entry charges
- Starter – generate 500 EUR in subscription/entry price quantity on each side of your binary staff
- Builder – generate 7000 EUR in subscription/entry price quantity on the weaker facet of your binary staff, 10,000 EUR on the stronger facet, and have one Starter or increased ranked affiliate on each side of the binary staff
- Sapphire – generate 15,000 EUR in subscription/entry price quantity on the weaker facet of your binary staff, 25,000 EUR on the stronger facet and have one Builder or increased ranked affiliate on each side of the binary staff
- Ruby – generate 30,000 EUR in subscription/entry price quantity on the weaker facet of your binary staff, 45,000 EUR on the stronger facet and have one Sapphire or increased ranked affiliate on each side of the binary staff
- Emerald – generate 70,000 EUR in subscription/entry price quantity on the weaker facet of your binary staff, 100,000 EUR on the stronger facet and have one Ruby or increased ranked affiliate on each side of the binary staff
- Diamond – generate 150,000 EUR in subscription/entry price quantity on the weaker facet of your binary staff, 250,000 EUR on the stronger facet and have one Emerald or increased ranked affiliate on each side of the binary staff
- Double Diamond – generate 400,000 EUR in subscription/entry price quantity on the weaker facet of your binary staff, 600,000 EUR on the stronger facet and have one Diamond or increased ranked affiliate on each side of the binary staff
- Triple Diamond – generate 1,000,000 EUR in subscription/entry price quantity on the weaker facet of your binary staff, 1,500,000 EUR on the stronger facet and have one Double Diamond or increased ranked affiliate on each side of the binary staff
- Crown Diamond – generate 2,500,000 EUR in subscription/entry price quantity on the weaker facet of your binary staff, 3,500,000 EUR on the stronger facet and have one Triple Diamond or increased ranked affiliate on each side of the binary staff
- Presidential Diamond – generate 4,000,000 EUR in subscription/entry price quantity on the weaker facet of your binary staff, 6,000,000 EUR on the stronger facet and have one Crown Diamond or increased ranked affiliate on each side of the binary staff
Referral Commissions
The Code subscription price funds generate a 20% referral fee.
100 EUR Xtera share investments pay a 6% referral fee.
Residual Commissions
The Code pays residual commissions through a binary compensation construction.
A binary compensation construction locations an affiliate on the high of a binary staff, break up into two sides (left and proper):
The primary stage of the binary staff homes two positions. The second stage of the binary staff is generated by splitting these first two positions into one other two positions every (4 positions).
Subsequent ranges of the binary staff are generated as required, with every new stage housing twice as many positions because the earlier stage.
Positions within the binary staff are crammed through direct and oblique recruitment of associates.
On the finish of a residual fee pay-period, The Code tallies up new Xtera share funding quantity throughout the binary staff.
Residual commissions are paid as 8% of Xtera share funding on the weaker binary staff facet.
As soon as paid out on, quantity is matched towards the stronger binary staff facet and flushed. Any leftover quantity on the stronger binary staff facet carries over.
Infinity Bonus
The Infinity Bonus pays an undisclosed proportion on The Code subscription price funds and Xtera share funding.
- unranked, Starter and Builder associates earn the Infinity Bonus on as much as 25,000 recruited associates
- Sapphire associates earn the Infinity Bonus on as much as 50,000 recruited associates
- Ruby associates earn the Infinity Bonus on as much as 75,000 recruited associates
- Emerald associates earn the Infinity Bonus on as much as 150,000 recruited associates
- Diamond associates earn the Infinity Bonus on as much as 250,000 recruited associates
- Double Diamond associates earn the Infinity Bonus on as much as 300,000 recruited associates
- Triple Diamond associates earn the Infinity Bonus on as much as 350,000 recruited associates
- Crown Diamond associates earn the Infinity Bonus on as much as 400,000 recruited associates
- Presidential Diamond associates earn the Infinity Bonus on all recruited associates who’re recruited after them
Observe that recruited associates for the Infinity Bonus could be straight or not directly recruited. All recruits after the qualifying affiliate joins are counted.
Management Pool
The Code takes 10% of month-to-month Xtera share funding and locations it right into a Management Pool.
The Management Pool is break up between Sapphire and better ranked associates throughout eight 1.25% smaller swimming pools.
Rank Achievement Bonus
The Code rewards associates for qualifying at Sapphire and better with the next one-time Rank Achievement Bonuses:
- qualify at Sapphire and obtain a “Sapphire Journey” valued at 500 EUR
- qualify at Ruby and obtain 1000 EUR
- qualify at Emerald and obtain an “Emerald Journey” valued at 2500 EUR
- qualify at Diamond and obtain a “luxurious watch” valued at 6500 EUR
- qualify at Double Diamond and obtain 50,000 EUR
- qualify at Triple Diamond and obtain a “tremendous automotive” valued at 200,000 EUR
- qualify at Crown Diamond and obtain “property” valued at 500,000 EUR
- qualify at Presidential Diamond and obtain 1,000,000 EUR
Becoming a member of The Code
The Code affiliate membership is through subscription:
- 49 EUR each 30 days; or
- 300 EUR for one year
Full participation within the in The Code’s hooked up revenue alternative requires a 100 EUR Xtera entry price and minimal 100 EUR funding in Xtera shares.
The Code Conclusion
Though it’s introduced as a third-party in The Code advertising and marketing…
…Xtera is probably going being run by the identical individuals working The Code.
- The Code’s web site area was registered in December 2024, Xtera’s web site area (“xtera.org”), was privately registered in January 2025
- The Code’s and Xtera’s web sites are each constructed on the “jswstheme” WordPress theme
Whereas Steve Mitchell and Michael Turner are introduced as The Code executives, the scheme is in any other case arrange as a typical Dubai MLM Ponzi.
From The Code’s web site Phrases and Situations:
The Code, Advertising and marketing and Mentoring Platform operates in choose jurisdictions. Our providers should not obtainable within the following nations and territories:
- United States of America (USA)
- Gulf Cooperation Council (GCC) nations (together with Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates)
There’s nothing unlawful about providing returns on shares within the US. Supplied after all an organization registers with the SEC and recordsdata well timed audited monetary experiences.
Scammers working fraudulent funding schemes will sometimes block US residents in an try to remain beneath the regulatory radar. Within the SEC, the US has probably the most energetic securities regulator on this planet.
There’s no cause to dam the UAE until The Code has an undisclosed tie to the nation. With Dubai being the MLM crime capital of the world, my cash is there.
Michael Turner being fluent in Russian and having ties to Ukraine matches in with Russian/Ukrainian scammers working out of Dubai.
That is after all hypothesis on my half. Name it an informed guess having seen this jap European rip-off template time and again.
Failure to register with the SEC would represent securities fraud for US resident funding into Xtera shares. The identical is true for any jurisdiction with a regulated monetary market.
The Code fails to supply proof it has registered its Xtera share scheme with monetary regulators in any jurisdiction.
As of February 2025, SimilarWeb was monitoring
- 60% of The Code’s web site visitors originating from Nigeria, adopted by 40% from Colombia
- 100% of Xtera’s web site visitors originating from the US
Because it stands, the one verifiable supply coming into the The Code is new Xtera share funding.
Utilizing new Xtera share funding to pay ROI withdrawals would make The Code a Ponzi scheme.
Moreover, with nothing marketed or offered to retail clients, the MLM facet of The Code operates as a pyramid scheme.
As with all MLM Ponzi schemes, as soon as affiliate recruitment dries up so too will new funding.
It will starve The Code of ROI income, finally prompting a collapse.
The maths behind behind Ponzi schemes ensures that after they collapse, the vast majority of contributors lose cash.
With many years of MLM expertise between them, Steve Mitchell, Michael Turner and Al Bala all positively know higher.