The best I can come up with is the RoboHelp help file. Look
for the HHACTIVEX.DLL index keyword which highlights the
"Distributing Microsoft HTML Help" topic. In there is a dropdown
link for "support files" which explicitedly mentions having to
distribute the file.
Personally I do not think it a worthwhile use of your time
persuing this. If distributing this file was against the RH licence
agreement there would be thousands of firms being taken through the
court by Adobe. It is just not an issue. It is tacit agreement that
if you accept the licence terms that you can freely distribute the
file.
This may not be what your company lawyers (or whoever is
persuing this) want. If it isn't, maybe they should contact Adobe
directly to get a definitive approval and stop wasting your time. I
suggest you put things a little more delicately than that though