Louise Nicholas, whose rape allegations led to the Commission of Inquiry into Police Conduct, says the new code of conduct for the force should specifically mention sexual misconduct.
Dame Margaret Bazley, who carried out the inquiry, recommended the code as a matter of urgency.
Although it lists 24examples of misconduct, there is no mention of sexual behaviour.
The Dominion Post reported today that Mrs Nicholas believed sexual misconduct had been the whole point of the commission.
"Part of the code of conduct was that sexual misconduct was to be addressed, and there's nothing in there," she said.
"Obviously the main issue has been left out."
National's police spokesman, Chester Borrows, agreed with Mrs Nicholas and said it was "strange" there was no mention of sexual misconduct.
Mr Borrows has questioned Police Minister Annette King through written parliamentary questions, and in her replies Ms King said sexual misconduct was covered by the code's general standards of behaviour.
