Certainly true, but for a slab on grade under living space (the kitchen mentioned in the OP), having standing water around the foundation would be a failure condition. The foundation drainage and site grading are supposed to prevent that.
Also, given the wording in 300.5(B) and 300.9, the question is just whether (a) the conduit is underground, (b) the conduit is in a wet location above grade, or (c) the interior of the conduit is considered a wet location for some other reason (maybe a section I missed?). If you buy the idea that a conduit in a slab on grade is both not "above grade" and not "underground" (not sure that I do, but it's worth considering), then the slab itself could be a wet location, but the interior of the conduit might not be a wet location.
At least, as an exercise in logic.
Cheers, Wayne