We are using this SIM card holder in one of our designs. The SIM card can be inserted into the slot and fixed/released by gently pushing it in. So the contacts are protected from touching.
Would you still consider adding the common ESD protection that is suggested in almost every related application note? I don't see the point in this case, but maybe I am missing something.
EDIT: I forgot to mention the fact, that the case of the device has to be opened to insert the SIM card. This normally happens only once or a few times during device life time. So ESD test equipment wouldn't even come near the card holder.