"21 race incidents" are quite a lot, so it could very well include stuff like littering, as it's part of Rule 8, "Failure to respect instructions, improper, dangerous or violent behaviour; damage to the environment or the image of the sport".
Carapaz got two strikes for littering in the 2022 Vuelta, for example.
Carapaz got two strikes for littering in the 2022 Vuelta, for example.