The Code Review: Xtera shares securities fraud

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 r

🤖 Quick Answer

What is The Code according to recent investigations?

Why has The Code raised regulatory concerns?
The organization fails to provide ownership and executive information on its website. Its leadership's background in multi-level marketing ventures and the recent domain registration have prompted scrutiny regarding potential securities fraud allegations.

What is Steve Mitchell's professional background?
Mitchell is a veteran of the multi-level marketing industry who has promoted numerous MLM companies including Monavie, Talk Fusion, Visalus, Modere, Melaleuca, and Le-Vel. He publicly announced retirement in April 2024 before subsequently joining The Code organization.

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