Everton manager Sean Dyche said it is "peculiar" that his club have reached the halfway point in the season without being awarded a penalty in the Premier League.
The only side in the 20-team English top flight not to have been given a spot kick, Everton, alongside Brighton & Hove Albion, Fulham, Tottenham Hotspur and Wolverhampton Wanderers, have also conceded the most penalties (five) this season.
"If you get to this stage of a season and you've not had a penalty, that's peculiar," Dyche told reporters ahead of Everton's game against Aston Villa.
"It is quite alarming when you see how many penalties are given for tiny touches which we can't work out sometimes. Some people see it as the 'modern game', but I find it alarming how many penalties are given for almost nothing.
"If that is the rule across the board then it goes against the stats that we haven't had a penalty. We will have to see if it balances up in the second half of the season."
Everton, who became the first Premier League club to be deducted points for breaching financial sustainability rules in November, are 17th in the league with 16 points from 20 matches. They host second-placed Villa at Goodison Park on Sunday.