The Code Review: The Code’s website lacks ownership details and was privately registered on December 4, 2024. Marketing videos feature COO Steve Mitchell.
CEO Michael Turner:
Steve Mitchell is an MLM veteran who, according to his website, has marketed NSA, Cabouchon, Euphony, Tiscali, FFI (Fuel Freedom International?), Monavie, Talk Fusion, Visalus, Modere, Melaleuca, Le-Vel, MWR Travel, and Velovita.
Mitchell’s retirement apparently didn’t work out.
Mitchell presents Michael Turner as follows in a prelaunch marketing film for The Code released on January 25th:
Michael has a PhD and is a distinguished physician. He is a dynamic, hands-on CEO with a track record of bringing about change and excellence globally, and he is a qualified Dale Carnegie trainer.
He has, for instance, run businesses in sixty-two nations. starting new businesses and overseeing billion-dollar brands and corporations.
He has worked with field teams, corporations, and individuals for more than 25 years. Additionally, he serves on Globee International’s board.
I would also want to welcome him as a guest presenter on Reuters International, iTV, and the BBC. Michael Turner is the CEO of The Code and a friend of mine.
Turner has MLM leadership experience via Nutrition For Life (2003-2005), according to his LinkedIn page. – Sales Manager for North Europe at MannaTech (2006-2009) (2009–2012) Director of International Business Development Agel – Vice President Europe, Middle East, and North Africa – President of EMEA Unicity International (2012-2019) – Vice President EURASIA Jeunesse (2019-2023) The general manager
Since January 2023, Turner has served on Globee International’s board.
On its website, the Code does not provide a business address. The Code is operated through a Seychelles shell company, according to the website’s Terms and Conditions. The Code, Marketing, and Mentoring Platform is registered under the Seychelles Companies Act and has the relevant licence from the Seychelles Licensing Authority (SLA), as specified by the Licenses Act 1986.
There are no known MLM regulations in the tax-haven nation of Seychelles. A red flag is raised right away when the Code is registered via a Seychelles shell company.
As always, you should carefully consider joining and/or transferring any funds if an MLM firm is not transparent about who owns or operates it.
There are no retailable goods or services in the Code.
The Code affiliate membership itself is the only thing that affiliates may advertise.
Affiliates of The Code register and pay for subscriptions:
Recruiting affiliate investors who also pay the aforementioned subscription/access fees is how The Code’s multilevel marketing division makes money.
Only 50% of affiliate withdrawal requests are paid in advance by the Code.
The remaining 50% is paid out over ten months at a drip-feed rate of 10% each month.
Within The Code’s payout structure, there are eleven affiliate tiers.
They are as follows, along with their corresponding qualifying requirements:
A 20% referral commission is generated by the Code subscription fee payments.
100 EUR Xtera share investments pay a 6% referral commission.
The Code uses a binary compensation scheme to pay residual commissions.
An affiliate at the top of a binary team, divided into left and right sides, is compensated according to a binary pay structure:
There are two places on the binary team’s initial level. These first two slots are divided into two more positions each, for a total of four positions, to create the binary team’s second level.
The binary team’s levels are created as needed, with each level holding twice as many spots as the one before it.
Affiliates are recruited both directly and indirectly to fill positions on the binary team.
The Code calculates the volume of fresh Xtera share investments made by the binary team at the conclusion of a residual commission pay period.
On the weaker binary team side, residual fees are paid out as 8% of the investment in Xtera shares.
Volume is flushed after being paid out on and compared to the stronger binary team side. The stronger binary team side retains any remaining volume.
An unknown proportion of The Code membership fee payments and Xtera share investments are paid out via The Infinity Bonus.
Keep in mind that affiliates that are recruited for the Infinity Bonus may be recruited directly or indirectly. After the qualified affiliate joins, all new recruits are counted.
10% of the monthly investment in Xtera shares is transferred to a Leadership Pool by the Code.
Sapphire and higher ranking affiliates are distributed among eight 1.25% smaller pools in the Leadership Pool.
Affiliates that qualify at Sapphire and above are rewarded by the Code with the one-time Rank Achievement Bonuses shown below:
Subscriptions for the Code affiliate membership cost 49 EUR per 30 days or 300 EUR for a full year.
A 100 EUR Xtera entry fee and a minimum investment of 100 EUR in Xtera shares are required in order to fully participate in the associated income possibility offered by The Code.
Most likely, the same individuals that are operating The Code are also running Xtera.
Although Michael Turner and Steve Mitchell are portrayed as executives of The Code, the program is essentially set up as a standard Dubai multilevel marketing scam.
Terms & Conditions from The Code’s website:
Only a few jurisdictions are served by the Code, Marketing, and Mentoring Platform. The following nations and territories do not provide our services:
Gulf Cooperation Council (GCC) nations, which include Saudi Arabia, Bahrain, Kuwait, Oman, Qatar, and the United Arab Emirates, and the United States of America (USA)
Offering returns on shares is not against the law in the United States. Assuming, of course, that a business submits timely audited financial reports and registers with the SEC.
US citizens are usually blocked by scammers operating fraudulent investment schemes in an effort to avoid detection by authorities. The SEC is the world’s busiest securities regulator in the United States.
Unless The Code has a secret connection to the UAE, there is no justification for blocking the nation. My money is in Dubai, which is the global center of multilevel marketing criminality.
Michael Turner fits in with Russian/Ukrainian fraudsters operating out of Dubai since he speaks Russian well and has Ukrainian connections.
Naturally, this is only conjecture on my side. After repeatedly seeing this fraud pattern from Eastern Europe, you may call it an informed estimate.
For US residents investing in Xtera shares, failure to register with the SEC would be securities fraud. This is true for every country where the financial market is controlled.
The Code does not provide proof that it has registered its Xtera share plan with any jurisdiction’s financial authority.
According to SimilarWeb, 60% of visitors to The Code’s website came from Nigeria as of February 2025, with Colombia accounting for 40% of all visits.
All visitors to Xtera’s website are from the United States.
New Xtera share investment is now the sole verified source entering the Code.
The Code would be a Ponzi scheme if ROI withdrawals were made using newly invested Xtera shares.
Additionally, The Code’s multilevel marketing (MLM) side functions as a pyramid scam as nothing is advertised or sold to retail consumers.
Like other MLM Ponzi scams, fresh money will stop coming in as soon as affiliate recruiting stops.
The Code will ultimately fail as a result of this deprivation of ROI income.
Ponzi schemes’ mathematical foundation ensures that most participants will lose money when they fail.
Together, Steve Mitchell, Michael Turner, and Al Bala have decades of MLM expertise, so they undoubtedly know better.
This The Code Review is based on publicly available information and does not constitute financial advice. Always conduct your own research (DYOR) and consult a professional before investing.
Always research before investing. Use these tools to verify legitimacy:
WHOIS Lookup: https://whois.domaintools.com
SimilarWeb: https://www.similarweb.com
ScamAdviser: https://www.scamadviser.co
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Trustpilot: https://www.trustpilot.com
Reddit Discussions: https://www.reddit.com
Given Meta Trade Fund Very low trust score, there is a good chance that the website is a hoax. Use caution when accessing this website!
Our algorithm examined a wide range of variables when it automatically evaluated Meta Trade Fund, including ownership information, location, popularity, and other elements linked to reviews, phony goods, threats, and phishing. All of the information gathered is used to generate a trust score.
Here are some frequently asked questions (FAQs) related to The Code Review article. These questions and answers are designed to address common concerns and provide additional clarity for readers:
The Code is an online platform, but it does not disclose ownership or executive details, raising transparency concerns.
The Code’s website does not reveal any ownership or executive information.
The domain thecode.marketing was privately registered on December 4, 2024.
Marketing videos linked to The Code feature COO Steve Mitchell.
Due to the lack of transparency regarding ownership and operations, it is advised to research thoroughly before engaging with The Code.
Title: The Code: Redefining Marketing & Mentorship for Growth
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