another 2.69 million non-Jewish Poles, 3.30 million Russian POWs in Germany, and a million Romani &c, one comes over 12 million; if you do not like counting exterminated POWs, you can still ask whether other civilian casualties (such as the 7 million Russians who died) can be regarded as victims of deliberate Nazi extermination (since, even if these mass deaths did not occur in death camps, the Nazis had a definite ideology of exterminating peoples they regarded as inferior)
See:
http://www.holocaust-history.org/~rjg/deaths.shtml