The Impartial Arbitrator shall decide whether any Club (or anyone acting on its behalf, e.g., Club employee or a member of a Club’s medical staff or Club medical consultant), willfully or negligently committed a material violation of the terms of this Agreement (including the Pain Management Guidelines, Club Reporting Requirements, the PDMP, and the Standardized Player Education). For purposes of finding a violation, it shall not matter whether or not the complaining party suffered any injury. The Impartial Arbitrator shall make findings of fact and determinations of relief, including without limitation, Club discipline.