If we're going to be super pedantic, the Common Lisp spec actually defines code as:
"code n. 1. Trad. any representation of actions to be performed, whether conceptual or as an actual object, such as forms, lambda expressions, objects of type function, text in a source file, or instruction sequences in a compiled file. This is a generic term; the specific nature of the representation depends on its context. "
A Lisp program is data. The Lisp system does not care if it comes from a text file or if it is constructed as data by a program: