It technically fits the broad definition of "code", besides the wordage "X as Code" conveys the meaning of treating X as if it is code by applying the same sort

It technically fits the broad definition of "code", besides the wordage "X as Code" conveys the meaning of treating X as if it is code by applying the same sort of tooling to maintain it (as if it were code). I feel sad for your students (if you really have any) for having such obtuse teacher.