Germany has indicted one HP employee and some former ones following a bribery investigation into a €35 million (£28 million) deal to supply Russia's General Prosecutor's Office with IT equipment.
The five-year deal, which ran from 2001 to 2006, involved a former subsidiary in Germany, according to HP's 10-Q filing on 10 September with the US Securities and Exchange Commission (SEC). The German probe also encompasses possible embezzlement and tax evasion, the document said.
In a written statement, HP said Wednesday that the company itself has not been charged, and it remains a "side participant" in the proceedings. The court has not decided if other HP entities will be side participants.
"HP is fully cooperating with the authorities," according to the statement. "HP has strict policies in place that require employees and partners to adhere to the highest standard of business ethics."
According to the 10-Q filing, the US is also investigating the Russian deal. The US Department of Justice and the SEC are examining if it violated the Foreign Corrupt Practices Act.
HP said that under the Act, a person or an entity could face penalties of up to $500,000 per violation and equitable remedies, and criminal penalties could range from $2 million (£1.2 million) per violation or twice the gross gain or loss from a violation.
US law enforcement has also requested information from other deals in Russia, Serbia and within the Commonwealth of Independent States subregion going back to 2000.
Authorities are seeking information related to two former HP employees seconded to Russia and whether company employees in Russia, Germany, Austria, Serbia, the Netherlands or the CIS region "were involved in kickbacks or other improper payments to channel partners or state-owned or private entities."