The code has 25 letters in it, which has multiples of 5 and 5:
Reading upwards from the bottom-left:
The code has 18 characters (14 letters, 4 numbers), it is a perfect candidate to attempt a transposition:
Reading downwards from the top-left:
The code looks like it is in the passcode format but there is a
1 which is not allowed in that format.
Using atbash on both the numbers and letters: