Windows uses SMB for remote file access as well (so if you play a file from a remote drive, it's using Windows SMB to access it - it works transparently to the application).
It's possible Kodi uses it's own SMB implementation, as it's a cross-platform application, but I think it's more likely that it doesn't use MMCS so the network throttling isn't triggered.
It's possible Kodi uses it's own SMB implementation, as it's a cross-platform application, but I think it's more likely that it doesn't use MMCS so the network throttling isn't triggered.