“UNFAIR ACTS”. The penalty for an Unfair Act is “unsportsmanlike like conduct.” That is the penalty the ref would call in the event of an Unfair Act.
They would not come out and say “Unfair Act” they would call “Unsportsmanlike conduct” as that is the penalty prescribed for an Unfair Act.
Not sure why you chose to leave that out of your definition…but it is right there in the rule book in black and white.
So…sorry…but you’re wrong on this one.