It is open to the commission to find that Allianz engaged in misconduct in relation to each of the misleading statements that were allowed to remain on its website, Ms Orr says.

Contravention of obligations in the Corporations Act by failing to report that misleading and deceptive conduct to ASIC could also have amounted to misconduct.

It also failed to have an adequate compliance system in place.

Ms Orr highlights a number of ways that Allianz engaged in behaviour falling below community standards, including by seeking to "manipulate" independent reports.

She says "for many years" Allianz has had inadequate processes for monitoring content on its own website, and inadequate processes for monitoring compliance incidents.

Ms Orr says monitoring and supervision "remains an issue" at Allianz.